HomeMy WebLinkAbout040728 - General - Contract - Eastern Research Group, Inc.-
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CITY SECRETARY
CONTRACT NO. L! P7 rd ~
CONTRACT
Between
CITY OF FORT WORTH
and
EASTJ:RN RESEARCH GROUP, IN(~.
For
I
Professional Services for Natural Gas Air Quality !
Study Final Work Plan I
DEM 10-05: NGAQS
Environmental Management Department
L __
August 2010
CITY SECRETARY
FT. WORTH, TX
08 -20 -1 0 P03 : 05 I N
I
I
M&C Rev iew Page 1 of 2
Official site of the City of Fort Worth, Texas
CITY COUNCIL AGENDA fO RT \VO RTH
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COUNCIL ACTION: Approved on 8/3/2010 -Ord. No. 19259-08-2010 & 19260-08-2010
DATE:
CODE:
8/3/2010 REFERENCE NO.: C-24375 LOG NAME:
C TYPE: PUBLIC
NON-CONSENT HEARING:
062040QAPP
NO
SUBJECT: Authorize the Execution of a Contract with Eastern Research Group, Inc ., in the Amount of
$600,000.00 for the Fort Worth Air Quality Study and Adopt Appropriation Ordinances (ALL
COUNCIL DISTRICTS)
RECOMMENDATION:
It is recommended that the City Council :
1. Suspend the Financial Policy Statements that limit the expenditure of gas lease revenue to one-time
capital items;
2. Adopt the attached appropriation ordinance increasing estimated receipts and appropriations in the
Capital Projects Reserve Fund -General Unrestricted Gas Lease Revenue by $600,000 .00 from available
funds;
3. Authorize the transfer of $600,000.00 from the Capital Projects Reserve Fund -General Unrestricted
Gas Lease Revenue to the General Fund;
4 . Adopt the attached supplemental appropriation ordinance increasing estimated receipts in the
General Fund by $600,000 .00 from available funds; and
5. Authorize the City Manager to execute a contract in the amount of $600 ,000.00 with Eastern
Research Group, Inc., for the Fort Worth Air Quality Study.
DISCUSSION:
The City Council established the Air Quality Committee on March 9, 2010 (Resolution No. 3866-03-2010).
This committee was tasked with identifying the study objectives , evaluating qualifications of consultants,
reviewing the scope of work with candidate consultants, and recommending a consultant and study
framework to the City Council. After reviewing the written submittals and conducting interviews, the
Committee has recommended Eastern Research Group , Inc. (ERG) for the Air Quality Study.
On July 20, 2010 (M&C C-24354) the City Council authorized a contract with ERG in the amount of
$50,000.00 to allow ERG to begin preliminary background work during July , 2010 . The initial phase of work
included ambient air monitoring network design and point source test plan development. Focus will be on
existing data regarding gas well sites and operations within Fort Worth as well as the scientific information
regarding sampling design , analys is methods and the quality assurance/quality control procedures to be
adhered to during the work .
The proposed contract will quantify the volume and mass of emissions from natural gas operations during
all phases of the natural gas drilling , production, and operational process . ERG will assess air quality
impacts to the community by quantifying emissions from point sources at multiple sites within Fort Worth
and then comparing point source emissions to thresholds that trigger air permits . An ambient air sampling
network will be setup to assess fence line impacts, setback distances under the City's ordinance and will
allow comparison to established regulatory standards. Dispersion modeling will be performed using
measured emissions at tested sites and such modeling will consider the effects of multiple emission
sources within a single site as well as the cumulative effects of numerous sites in concentrated areas .
Both point source and ambient air sampling will quantify levels of benzene , methane , ethane and total
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M&CReview Page 2 of2
volatile organic compounds (VOC). Additionally, applicable emission sources will be sampled for nitrogen
oxide (NOx), sulfur-containing organic compounds, formaldehyde and particulate matter (PM) emissions.
ERG will adhere to strict quality assurance and quality control procedures including preparation and
adherence to a project specific Quality Assurance Project Plan (QAPP).
The contract is expected to be complete in March 2011 with sampling and field work occurring from August
through November 2010.
The current Financial Management Policy Statements limit the usage of the gas lease revenues to one-time
capital expenses . However, staff recommends suspending the rules in order to allow the use of the funds
for the purposes of an air quality study that is directly related to the production of minerals.
Eastern Research Group , Inc. is in compliance with the City's M/WBE Ordinance by committing to 10
percent M/WBE participation on this contract and the preliminary background work associated with this
study. The City's goal on this project is 10 percent.
This work will affect ALL COUNCIL DISTRICTS.
FISCAL INFORMATION/CERTIFICATION:
The Financial Management Services Director certifies that upon approval of the above recommendations
and adoption of the attached supplemental appropriation ordinances, funds will be available in the current
capital budget of the Capital Projects Reserve Fund and the current operating budget of the General Fund.
TO Fund/Account/Centers
2) GC10 446100 006060001000 $150,000.00
2) GC10 446200 006060001000 $450.000 .00
2) GC10 538070 006060001000 $600.000 .00
4) GG01 539120 0062040 $600.000.00
3) 4) GG01 472010 0062040 $600.000.00
Submitted for City Manager's Office by:
Originating Department Head:
Additional Information Contact:
ATTACHMENTS
062040QAP Rec 2 .doc
062040QAP Rec 4 .doc
FROM Fund/Account/Centers
3 GC10 538070 006060001000 $600.000.00
5) GG01 539120 0062040
Fernando Costa (6122)
Susan Alanis (8180)
Jean Petr (8367)
$600,000 .00
http://apps.cfwnet.org/ council_packet/mc _review .asp?ID= 13946&councildate=8/3/2010 8/27 /2010
ST A TE OF TEXAS
COUNTY OF TARRANT
§
§
§
KNOWN ALL BY THESE PRESENTS :
CONTRACT FOR PROFESSIONAL SERVICES
DEM : 10-05 -NATURAL GAS AIR QUALITY STUDY
FINAL WORK PLAN
Th is Contract is entered into by and between the City of Fort Worth ("City "), a home-rule
mun icipal ity located w ithin Tarrant, Denton , Parker, and Wise Counties , Texas , acting
through Fernando Costa , its duly authorized Assistant City Manager, and Eastern
Research Group , Inc ., a Massachusetts corporation ("Contractor"), acting through John
Eyraud , its duly authorized Vice President. C ity and Contractor may be referred to
herein individually as a Party , or collectively as the Parties .
WITNESS ETH :
That for and in consideration of mutual covenants and agreements herein conta i ned ,
the Parties hereto mutually agree as follows :
ARTICLE 1.
DEFINITIONS
City means the City of Fort Worth .
Change Order means an offic ially authorized and executed written amendment to this
contract or to a Task Order, issued by the City .
Contract Documents shall consist of the written , printed , typed and drawn instruments
which comprise and govern the performance of the work. Said Contract Documents
include , but are not limited to , the Request for Qualifications (RFQ), addenda to the
RFQ , the Statement of Qualifications , work plan , proposals , other p lans , specificat ions ,
maps , blueprints , notice of award , general conditions , special conditions , supplementary
conditions , general provisions , special provisions , task order(s), work order(s ), change
orders , amendments , this Contract and the payment , performance , and maintenance
bonds . The Contract Documents shall also include any and all supplemental
agreements approved by the City which may be necessary to complete the work i n
accordance with the intent of the plans and specifications in an acceptable manner, and
shall also include the additional instruments bound herewith .
Contractor means Eastern Research Group , Inc .
Profess ional Serv ices Contract
A ir Quality Study -Final Work Plan
Eastern Research G roup , Inc.
OFFICIAL RECORD
CITY SECRE'TARY
FT 'NORTH TX
Pag e 1 of 73
Final Work Plan or Work Plan means the document ent itled "City of Fort Worth Natural
Gas Air Quality Study -Final Work Plan ".
Notice to Proceed means the official letter issued by the City , pursuant to the Code of
the City of Fort Worth and City ordinances and policies that authorizes Contractor to
begin work .
Task Order means an officially authorized and executed written description and
specification directing the Contractor to perform specific services within the scope of this
contract , issued by the City . ·
ARTICLE 2.
SERVICES
Contractor hereby agrees to perform as an independent contractor the services set forth
in the Scope of Work attached hereto as Attachment "A ".
Th is contract is to provide the City of Fort Worth with professional services for an
assessment of the air quality impacts related to natural gas facilities (Air Quality Study).
This contract is for work to be performed for the City of Fort Worth Air Quality Study as
described in the City of Fort Worth Council Resolution Number 3866 , City of Fort Worth
Request for Qualifications DEM10 -05 : NGAQS , and the Contractor 's Final Work Plan .
Nothing in this contract is to be const rued as an exclusive agreement with the contractor
to provide the City with profess ional services of this type or as an agreement by the City
to guarantee the Contractor any specific projects or quantities of work . THERE IS NO
MINIMUM GUARANTEE OF ANY WORK UNDER THIS CONTRACT OR ANY
GUARANTEE OF ADDITIONAL FUTURE WORK OTHER THAN AS STRICTLY
DEFINED BY THIS CONTRACT .
Individual projects will be authorized on a Task Order basis when the City elects to
proceed with each specific effort . City shall not pay for any work performed by
Contractor or its subcontractors , subcontractors and/or suppliers that has not been
specifically ordered by the City in writing on a duly executed Task Order or Change
Order . Contractor shall not be compensated for any work that is verbally ordered by
any person and shall rely only upon written authorizat ion to conduct work .
ARTICLE 3.
COMPENSATION
Section 1.
Fee Schedule .
City and Contractor agree to the unit pr ices , employee labor rates , and other costs as
specified in this contract. Contractor shall be compensated in accordance with the Fee
Schedule shown in Attachment "B". Payment shall be considered full compensation for
Profess iona l Serv ices Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc . Page 2 of 73
all labor, materials, supplies , and equipment necessary to complete the services
described in Attachment "A ". However the total fee paid by the City shall not exceed a
total of six hundred thousand dollars ($600,000 .00) and the City will not be liable for any
Contractor fees, costs, or other remuneration in excess of this amount unless the City
has signed and issued a formal and duly authorized modification , amendment, or
change order to this contract.
Section 2.
Task Orders.
City will issue a Task Order to Contractor that details the work to be performed by the
Contractor. Task Orders will include at a minimum a unique Task Order Number,
project address , scope of work, date to commence work , time period to complete work
and the not to exceed payment amount for the task .
Section 3.
Invoice and Payment.
The Contractor shall provide monthly invoices to the City . All invoices must reflect the
City Task Order number. Invoices shall contain a detailed breakdown to include : labor
including employee name, functional title , date and hours of work performed ; internal
supplies and services provided; and external supplies and services provided .
Payment for services rendered shall be due within thirty (30) days of the uncontested
performance of the particular services so ordered and receipt by City of Contractor 's
invoice for payment of same . In the event of a disputed or contested billing , only that
portion so contested may be withheld from payment , and the undisputed portion will be
paid . No interest will accrue on any contested portion of the billing until mutually
resolved . City will exercise reasonableness in contesting any billing or portion thereof.
The Contractor shall also provide the City with quarterly updates showing the total and
itemized costs incurred to the City for each task ordered and the amount remaining in
the contract not-to-exceed amount.
Contractor shall receive no additional compensation for work delays or hindrances
except when direct and unavoidable extra costs to the Contractor are caused by the
City 's gross negligence .
ARTICLE 4.
TIME TO COMPLETE THE PROJECT
Contractor shall complete work under this contract in accordance with the schedule in
the Work Plan , subject to extensions of time as specified in a task order or if an
extension of time is granted in a duly authorized contract amendment or modification .
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc . Page 3 of 73
In addition , the City may authorize an extension in the time to complete the work for
good cause if delays are encountered due to events that are beyond the control of the
Contractor . It shall be the duty of the Contractor to notify the City in writing of any
events that may cause a delay in the completion of a task or the project as soon as
practicable to allow the parties to mitigate any such delay .
The final determination for any extension in the time to complete the project or any task
shall be made in the sole judgment and discretion of the City of Fort Worth and shall not
be unreasonably withheld .
Should the Contractor fail to begin the work herein provided for with in the time herein
fixed or to carry on and complete the same according to the terms of the Contract
Documents , then the City shall have the right to either (1) demand that the Contractor's
surety take over the work and complete same in accordance with the plans ,
specificat ions and other Contract Documents or (2) to take charge of and complete the
work in such a manner as it may deem proper, and if in the completion thereof, the cost
to City shall exceed the contract price or prices set forth in the Contract Documents , the
Contractor and/or its surety shall pay City upon its demand in a writing , setting forth and
specifying an itemized statement of the total cost thereof, said excess cost.
ARTCLE 5.
RESERVED
ARTICLE 6 .
TERM
Unless terminated pursuant to the terms herein , this Agreement shall be for a term of
one year beginning upon the date of its execution or upon completion of the work as
described within the scope of work , wh ichever occurs later.
ARTICLE 7.
INDEPENDENT CONTRACTOR
Contractor shall operate hereunder as an independent contractor , and not as an officer ,
agent , servant , or employee of the City . Contractor shall have exclus ive control of and
the exclusive right to control the details of its work to be performed hereunder and all
persons performing same , and shall be solely responsible for the acts and omissions of
its officers , agents , employees , contractors and subcontractors . The doctrine of
respondeat superior shall not apply as between City and Contractor, its officers , agents ,
employees , contractors , and subcontractors , and nothing herein shall be construed as
creating a partnership or joint venture between City and Contractor .
Professiona l Serv ices Contract
Ai r Quality Study -Final Work Plan
Eastern Research Group , Inc. Page 4 of 73
ARTICLE 8.
PROFESSIONAL COMPETENCE
Work performed by Contractor shall comply in all aspects with all applicable local , state
and federal laws and with all applicable rules and regulations promulgated by the local ,
state and national boards , bureaus and agencies . Approvals issued by the City or
another entity shall not constitute or be deemed to be a release of the responsibility and
liability of Contractor or its officers , agents , employees , contractors and subcontractors
for the accuracy and competency of its services performed hereunder , which shall be
performed in accordance with the applicable professional standard of care.
ARTICLE 9 .
INTELLECTUAL PROPERTY
Section 1.
Rights in data .
The City shall have unlimited rights in all data delivered under this contract , and in all
data first produced in the performance of this contract.
Section 2.
Intellectual property rights and ownership .
All intellectual property work product developed by Contractor under this contract shall
be the sole property of the City and the City shall have unlimited rights in such work
product. All intellectual property work product developed by Contractor under this
contract shall be considered "work for hire " and rights , title , and interests to all
intellectual property shall vest in the City . Contactor affirmatively , by executing this
contract , disclaims all such intellectual property interests in favor of the City .
In the event that any rights , title, or interest shall by operation of law or otherwise fail to
vest in the City or become void or voidable , Contractor agrees to a) transfer all rights ,
title , and interest to intellectual property to the City ; or alternatively and at the discretion
of the City the Contractor shall b) grant an unlimited and exclusive license for
publication , sale , reproduction , or use by the City and its authorized sublicensees of all
intellectual property developed under this contract. Contractor agrees to timely execute
any documents or take any other actions as may reasonably be necessary , or as the
State may reasonably request , to perfect the State 's ownersh ip, license , or other rights
to any work product.
Contractor shall not use , sell, transfer , or authorize a third party to use any work
product, copyrights , trademarks , or other intellectual property (or derivatives thereof) of
the work product developed under this contract without the express written consent of
the City .
Professiona l Services Contract
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Eastern Research Group , Inc. Page 5 of 73
ARTICLE 10.
INDEMNIFICATION
Section 1.
Definitions .
In this paragraph , the follow ing words and phrases shall be defined as follows :
Environmental Damages shall mean damages which are incurred as a result of
negligence , an intentional tort , or a violation of environmental requirements pertaining to
work performed under this contract by the operations of the Contractor and
Subcontractors , and including without limitation :
a. Damages for personal injury and death , or injury to property or natural
resources ;
b. Fees incurred for the services of attorneys , consultants , contracto rs , experts ,
laboratories and other reasonable costs required by any federal , state or local
governmental agency or otherwise expended to remedy the environmental
damages includ ing any attorney 's fees , costs and expenses incurred in
enforcing this contract or collecting any sums due hereunder; and
c. Liability to any third person or governmental agency to indemnify such person
or agency fo r costs expended in connection with the items referenced in
subparagraph (b) here in.
Environmental requirements shall mean all applicable to the work performed under this
agreement (or which may become applicable during the term of this agreement)
statutes , regulations , rules , plans , authorizations , concessions , franchises , and similar
items , of all governmental agencies , departments , commissions , boards , bureaus , or
instrumentalities of the United States , states , and political subdivisions thereof and all
applicable judicial , administrative , and regulatory decrees , judgments , and orders
relating to the protection of human health or the environment, including without
limitation :
a. All requirements , includ ing , but not limited to , those pertaining to reporting ,
licensing , emissions , discharges , releases , or threatened releases of
hazardous materials , pollutants , contaminants or hazardous or toxic
substances , materials , or wastes whether solid , liquid , or gaseous in nature ,
into the air , surfacewater , groundwater , stormwater , or land , or relating to the
manufacture , processing , distribution , use , treatment , storage , disposal ,
transport , or handl ing of pollutants , contaminants , or hazardous or toxic
substances , materials , or wastes , whether solid , liquid , or gaseous in nature ;
and
Profess ional Services Contract
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b. All requirements pertaining to the protection of the health and safety of
employees or the public.
Section 2.
General Indemnification. CONTRACTOR DOES HEREBY RELEASE, INDEMNIFY,
REIMBURSE , DEFEND, AND HOLD HARMLESS THE CITY, ITS OFFICERS,
AGENTS, AND EMPLOYEES, FROM AND AGAINST ANY AND ALL LIABILITY,
CLAIMS , SUITS, DEMANDS, OR CAUSES OF ACTIONS WHICH MAY ARISE DUE
TO ANY LOSS OR DAMAGE TO PERSONAL PROPERTY , OR PERSONAL INJURY,
AND/OR DEATH, OCCURRING AS A CONSEQUENCE OF THE CONTRACTOR'S
OPERATIONS UNDER THIS AGREEMENT, WHEN SUCH INJURIES, DEATH, OR
DAMAGES ARE CAUSED BY THE SOLE NEGLIGENCE OF CONTRACTOR , ITS
OFFICERS , AGENTS, EMPLOYEES, OR CONTRACTORS, OR THE JOINT
NEGLIGENCE OF CONTRACTOR, ITS OFFICERS, AGENTS , EMPLOYEES, OR
CONTRACTORS AND ANY OTHER PERSON OR ENTITY.
Section 3.
Environmental Indemnification. CONTRACTOR DOES HEREBY RELEASE,
INDEMNIFY, DEFEND , REIMBURSE, AND HOLD HARMLESS THE CITY, ITS
OFFICERS, AGENTS, AND EMPLOYEES , AGAINST ANY AND ALL
ENVIRONMENTAL DAMAGES AND THE VIOLATION OF ANY AND ALL
ENVIRONMENTAL REQUIREMENTS RESULTING FROM CONTRACTOR'S
OPERATIONS UNDER THIS AGREEMENT WHEN SUCH ENVIRONMENTAL
DAMAGES OR VIOLATION OF ENVIRONMENTAL REQUIREMENTS ARE CAUSED
BY THE ACT OR OMISSION OF CONTRACTOR, ITS OFFICERS, AGENTS,
EMPLOYEES, OR CONTRACTORS, OR THE JOINT ACT OR OMISSION OF
CONTRACTOR, ITS OFFICERS, AGENTS, EMPLOYEES, OR CONTRACTORS AND
ANY OTHER PERSON OR ENTITY AND WHICH ARE DIRECTLY RELATED TO
EITHER (i) NEGLIGENCE; OR (ii) INTENTIONAL OR WILLFUL MISCONDUCT.
Section 4.
The obligations of the Contractor under this Article shall include , but not be limited to,
the burden and expense of defending all claims , suits and administrative proceedings
(with counsel reasonably approved by the City) and conducting all negotiations of any
description, and paying and discharging, when and as the same become due, any and
all judgments, penalties or other sums due against such indemnified persons.
Upon learning of a claim, lawsuit , or other liability which Contractor is required
hereunder to indemnify, City shall provide Contractor with reasonable timely notice of
same .
Professional Services Contract
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All Contractors under this contract agree that they assume joint and several liability for
any claim by the City or for a third party claim against the City for general or
environmental damages caused by any of the Contractors herein.
The obligations of the Contractor under this paragraph shall survive the expiration or
termination of this Agreement and the discharge of all other obligations owed by the
parties to each other hereunder.
ARTICLE 11.
INSURANCE AND BONDS
The Contractor certifies it has, at a minimum, current insurance coverage as detailed
below and will maintain it throughout the term of this Contract. Prior to commencing
work, the Contractor shall deliver to City, certificates documenting this coverage. The
City may elect to have the Contractor submit its entire policy for inspection.
A. Insurance coverage and limits:
1.
2.
3.
4 .
Commercial General Liability
o $1,000,000 each occurrence
o $2,000,000 aggregate
Automobile Liability
o $1,000,000 each accident, or
o $250,000 property damage/ $500,000 bodily injury per person per accident
A commercial business auto policy shall provide coverage on "any auto," defined as
autos owned, hired and non-owned during the course of this project.
The named insured and employees of Contractor shall be covered under this
policy. The City of Fort Worth shall be named an Additional Insured, as its
interests may appear. Liability for damage occurring while loading, unloading and
transporting materials collected under the Contract shall be included under this
policy.
Worker's Compensation
o Coverage A: statutory limits
o Coverage B: $100,000 each accident
Professional Liability
$500,000 disease -policy limit
$100,000 disease -each employee
o $1,000,000 each claim
o $2,000,000 aggregate
Professional Services Contract
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5.
The retroactive date shall be coincident with or prior to the date of this contract and
the certificate of insurance shall state that the coverage is claims-made and the
retroactive date. The insurance coverage shall be maintained for the duration of
this contract and for five (5) years following completion of the contract (Tail
Coverage). This provision shall survive the one year term of this contract. An
annual certificate of insurance shall be submitted to the City for each year following
completion of this contract.
Environmental Impairment Liability and/or Pollution Liabil ity
o $2 ,000,000 per occurrence .
Ell coverage(s) must be included in policies listed in the professional liability
insurance above; or, such insurance shall be provided under a separate policy or
policies. Liability for damage occurring while loading , unloading and transporting
materials collected under the contract project shall be included under the
Automobile Liability insurance or other policy(s).
B. Certificates of Insurance evidencing that the Contractor has obtained all requ ired
insurance shall be delivered to the City prior to Contractor proceeding with the
Contract.
1. Applicable policies shall be endorsed to name the City an Additional Insured
thereon, as its interests may appear. The term City shall include its employees,
officers , officials , agents , and volunteers as respects the Contracted services ..
2 . Certificate(s) of Insurance shall document that insurance coverage specified
herein are provided under applicable policies documented thereon.
3. Any failure on part of the City to request required insurance documentation shall
not constitute a waiver of the insurance requirements.
4 . A minimum of thirty (30) days notice of cancellation or material change in
coverage shall be provided to the City. A ten (10) days notice shall be acceptable
in the event of non-payment of premium . Such terms shall be endorsed onto
Contractor's insurance policies. Notice shall be sent to Department of Risk
Management, City of Fort Worth , 1000 Throckmorton Street, Fort Worth, Texas
76102 .
5 . Insurers for all policies must be authorized to do business in the state of Texas or
be otherwise approved by the City; and , such insurers shall be acceptable to the
City in terms of their financial strength and solvency.
6 . Deductible limits, or self-insured retentions, affecting insurance required herein
shall be acceptable to the City in its sole discretion; and, in lieu of traditional
insurance, any alternative coverage maintained through insurance pools or risk
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retention groups must be also approved. Dedicated financial resources or Letters
of Credit may also be acceptable to the City .
7. Applicable policies shall each be endorsed with a waiver of subrogation in favor
of the City as respects the Contract.
8. The City shall be entitled, upon its request and without incurring expense, to
review the Contractor's insurance policies including endorsements thereto and, at
the City's discretion; the Contractor may be required to provide proof of insurance
premium payments.
9. The Commercial General Liability insurance policy shall have no exclusions by
endorsements unless the City approves such exclusions .
10. The City shall not be responsible for the direct payment of any insurance
premiums required by the contract. It is understood that insurance cost is an
allowable component of Contractor's overhead.
11. All insurance required above shall be written on an occurrence basis in order to
be approved by the City.
12 . Subcontractors to the Contractor shall be required by the Contractor to maintain
the same or reasonably equivalent insurance coverage as required for the
Contractor. When subcontractors maintain insurance coverage, Contractor shall
provide City with documentation thereof on a certificate of insurance.
Notwithstanding anything to the contrary contained herein, in the event a
subcontractor's insurance coverage is canceled or terminated, such cancellation
or termination shall not constitute a breach by Contractor of the contract.
13 . Payment and Performance Bonds. Before beginning the work, the Contractor
shall be required to execute to the City of Fort Worth a payment bond if the
contract is in excess of $50,000 and a performance bond if the contract is in
excess of $100,000. The payment bond is solely for the protection and use of
payment bond beneficiaries who have a direct contractual relationship with the
Contractor or subcontractor to supply labor or material; and in 100% the amount
of the Contract. The performance bond is solely for the protection of the City of
Fort Worth, in 100% the amount of the Contract, and conditioned on the faithful
performance by Contractor of the work in accordance with the plans,
specifications, and contract documents . Contractor must provide the payment
and performance bonds, in the amounts and on the conditions required , within 14
calendar days after Notice of Award.
14. Requirements for Sureties . The bonds shall be issued by a corporate surety duly
authorized and permitted to do business in the State of Texas that is of sufficient
financial strength and solvency to the satisfaction of the City. The surety must
meet all requirements of Article 7 .19-1 of the Texas Insurance Code. All bonds
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furnished hereunder shall meet the requirements of Chapter 2253 of the Texas
Government Code, as amended.
In addition, the surety must (1) hold a certificate of authority from the United
States Secretary of the Treasury to qualify as a surety on obligations permitted or
required under federal law; or (2) have obtained reinsurance for any liability in
excess of $100,000 from a reinsurer that is authorized and admitted as a
reinsurer in the state of Texas and is the holder of a certificate of authority from
the Untied States Secretary of the Treasury to qualify as a surety on obligations
permitted or required under federal law. Satisfactory proof of any such
reinsurance shall be provided to the City upon request. The City, in its sole
discretion, will determine the adequacy of the proof required herein.
No sureties will be accepted by the City that are at the time in default or
delinquent on any bonds or which are interested in any litigation against the City.
Should any surety on the Contract be determined unsatisfactory at any time by
the City, notice will be given to the Contractor to that effect and the Contractor
shall immediately provide a new surety satisfactory to the City.
ARTICLE 12 .
LICENSES AND PERMITS
Contractor certifies and warrants that on the day any work is to commence under this
contract and during the duration of the contract it shall have and maintain all of the
current, valid, and appropriate federal, state, and local licenses and permits necessary
for the provision of services under this contract.
Contractor also certifies that if it uses any subcontractor in the performance of this
contract , that such subcontractor shall have and maintain all of the current, valid , and
appropriate federal, state , and local licenses and permits necessary for the provision of
services under this contract.
ARTICLE 13.
TRANSFER OR ASSIGNMENT
City and Contractor each bind themselves, and their lawful successors and assigns, to
this Agreement. Contractor has been engaged as a consequence of Contractor's
specific and unique skills; Assignment will only be granted under unusual circumstances
and at the sole discretion of the City . Contractor, its lawful successors and assigns,
shall not assign, sublet or transfer any interest in this Agreement without prior written
consent of the City.
Professional Services Contract
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ARTICLE 14.
RIGHT TO AUDIT
(a) Contractor agrees that the City shall, until the expiration of three (3) years after final
payment under this Agreement, have access to and the right to examine any directly
pertinent books, documents, papers and records of Contractor involving transactions
relating to this Agreement. Contractor agrees that the City shall have access during
normal working hours to all necessary facilities and shall be provided adequate and
appropriate workspace in order to conduct audits in compliance with the provisions
of this section. City shall give Contractor reasonable advance notice of intended
audits. A City initiated audit of indirect costs shall be conducted by review of an
appropriate existing audit by recognized federal agency if such data is made
available for review to the City.
(b) Contractor further agrees to include in all its subcontracts hereunder, a provision to
the effect that the subcontracting contractor agrees that the City shall, until the
expiration of three (3) years after final payment under the subcontract, have access
to and the right to examine any directly pertinent books, documents, papers and
records of such subcontractor, involving transactions to the subcontract, and further,
that City shall have access during normal working hours to all subcontractor
facilities, and shall be provided adequate and appropriate work space in order to
conduct audits in compliance with the provisions of this article. City shall give
Contractor and any subcontractor reasonable advance notice of intended audit.
(c) Contractor and subcontractors agree to photocopy such documents as may be
requested by the City. The City agrees to reimburse Contractor for the cost of copies
at the rate published in the Texas Administrative Code in effect as of the time copying
is performed.
ARTICLE 15.
MINORITY AND WOMAN BUSINESS ENTERPRISE
(M/WBE) PARTICIPATION
In accordance with City Ordinance No. 15530, the City has goals for the participation of
minority business enterprises and woman business enterprises ("M/WBE") in City
contracts. Contractor agrees to a minimum M/WBE participation of ten percent ( 10 % )
in accordance with its proposal and the aforementioned ordinance. Contractor
acknowledges the M/WBE goal established for this Agreement and its commitment to
meet that goal. For the purposes of determining M/WBE participation the full 10%
M/WBE participation is calculated using the combined total work performed under this
contract and the prior contract for work (CS-40631) on the Air Quality Study . Any
misrepresentation of facts ( other than a negligent misrepresentation) and/or the
commission of fraud by the Contractor may result in the termination of this Agreement
and debarment from participating in City contracts for a period of time of not less than
three (3) years.
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ARTICLE 16 .
NON-DISCRIMINATION
During the performance of this contract, Contractor shall not discriminate in its
employment practices and shall comply with all applicable provisions of Chapter 17 ,
Article Ill of the Code of the City of Fort Worth .
Contractor agrees not to discriminate against any employee or applicant for
employment because of because of age , race , color , religion , sex , disability , national
origin , sexual orientation , transgender, gender identity or gender express ion in any
manner involving employment, including the recruitment of appl icants for employment ,
advertising, hiring, layoff, recall, termination of employment , promotion, demotion ,
transfer, compensation, employment classification , training and selection for training or
any other terms , conditions or privileges of employment.
Contractor agrees to post in conspicuous places , available to employees and applicants
for employment , notices setting forth the provisions of the non-discrimination clause .
Contractor also agrees that in all solicitations or advertisements for employees placed
by or on behalf of this contract , that Contractor is an equal opportunity employer .
Notices , advertisements, and solicitations placed in accordance with federal law , rule or
regulation shall be deemed sufficient for the purpose of meeting the requirements of this
section.
ARTICLE 17 .
OBSERVE AND COMPLY
Contractor shall at all times observe and comply with all federal , state , and local laws and
regulations and with all City ordinances and regulations which in any way affect this
Agreement and the work hereunder, and shall observe and comply with all orders , laws
ordinances and regulations which may exist or may be enacted later by governing bodies
having jurisdiction or authority for such enactment. No plea of misunderstanding or
ignorance thereof shall be considered .
ARTICLE 18 .
DEFAULT
If Contractor fails to begin work or to complete work within the time specified in a Task
Order City shall have the right to take charge of and complete the work in such a manner
as it deems appropriate . If the City exceeds the costs detailed herein or in the Task Order ,
City may deliver to Contractor a written itemized statement of the excess costs and
Contractor shall reimburse the City for such excess costs without d.elay .
If at · any time during the terms of this contract, the work of the Contractor fails to meet the
specifications of the Contract Documents or to meet the standards of duty , care , or
proficiency of a reasonable and competent Contractor, City may notify the Contractor of
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the deficiency in writing . Failure of the Contractor to correct such deficiency and complete
the work required under this contract or a Task Order to the satisfaction of the City within
ten (10) days after written notice shall constitute default, and shall result in termination of
this contract.
Contractor shall not be deemed to be in default because of any failure to perform under
this contract if the failure arises solely acts of God , acts of war or terrorism , fires , floods ,
epidemics , quarantine restrictions , labor strikes , freight embargoes, and events of
unforeseeably severe weather.
ARTICLE 19 .
TERMINATION
City may terminate this contract without cause by giving thirty (30) days written notice to
Contractor . In the event of termination , any work in progress will continue to completion
unless otherwise specified in the notice of termination . If the City terminates this contract
under this provision , City shall pay Contractor for all services performed prior to the
termination . Termination shall be without prejudice to any other remedy the City may
have .
All data and completed or partially completed documents prepared under this contract
shall be promptly turned over to the City upon termination of this contract.
ARTICLE 20 .
VENUE AND JURISDICTION
If any action , whether real or asserted , at law or in equity, arises on the basis of any
provision of this Agreement, venue for such action shall lie in state courts located in
Tarrant County, Texas or the United States District Court for the Northern District of
Texas -Fort Worth Division. This Agreement shall be construed in accordance with the
laws of the State of Texas.
ARTICLE 21 .
CONTRACT CONSTRUCTION
The Parties acknowledge that each party and, if it so chooses , its counsel have
reviewed and revised this Agreement and that the normal rule of construction to the
effect that any ambiguities are to be resolved against the drafting party must not be
employed in the interpretation of this Agreement or any amendments or exhibits hereto .
ARTICLE 22 .
HEADINGS
The headings contained herein are for the convenience in reference and are not
intended to define or limit the scope of any provision of this Agreement.
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ARTICLE 23 .
COUNTERPARTS
This Agreement may be executed in one or more counterparts and each counterpart
shall , for all purposes, be deemed an original, but all such counterparts shall together
constitute but one and the same instrument.
ARTICLE 24 .
SEVERABILITY
The prov1s1ons of this Agreement are severable , and if any word, phrase , clause ,
sentence, paragraph , section or other part of this Agreement or the application thereof
to any person or circumstance shall ever be held by any court of competent jurisdiction
to be invalid or unconstitutional for any reason , the remainder of this Agreement and the
application of such word , phrase, clause , sentence , paragraph , section , or other part of
this Agreement to other persons or circumstances shall not be affected thereby and this
Agreement shall be construed as if such invalid or unconstitutional portion had never
been contained therein .
ARTICLE 25.
RIGHTS AND REMEDIES NOT WAIVED
In no event shall the making by the City of any payment to Contractor constitute or be
construed as a waiver by the City of any breach of covenant , or any default which may
then exist , on the part of Contractor, and the making of any such payment by the City while
any such breach or default exists shall in no way impair or prejudice any right or remedy
available to the City with respect to such breach or default. Any waiver by either party of
any provision or condition of the contract shall not be construed or decreed to be a waiver
of any other provision or condition of this Contract, nor a waiver of a subsequent breach of
the same provis ion or condition , unless such waiver be expressed in writing by the party to
be bound .
All costs and attorneys fees incurred by the City in the enforcement of any provision of this
contract shall be paid by the Contractor.
The remedies provided for herein are in addition to any other remedies available to the
City elsewhere in this contract and by law.
ARTICLE 26 .
NOTICES
Notices to be provided hereunder shall be sufficient if forwarded to the other Party by
hand-delivery or via U .S. Postal Service certified mail return receipt requested , postage
prepaid , to the address of the other Party shown below :
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If to the City :
If to the Contractor :
City of Fort Worth
Environmental Management Department
Attn : Brian Boerner , CPM , CHMM , Director
1000 Throckmorton Street
Fort Worth , Texas 76102-6311
Eastern Research Group , Inc.
Attn: Linda Taylor
110 Hartwell Avenue
Boston , MA 02421
ARTICLE 27 .
WARRANTY
Contractor warrants that it understands the currently known hazards and suspected
hazards which are presented to persons , property and the environment by the types of
work which are to be perfo rmed under this contract.
Contractor further warrants that it will perform all serv ices under this Contract in a safe ,
efficient and lawful manner using industry accepted practices , and in full compliance
with all applicable state and federal laws governing its activities and is under no restraint
or order which would prohibit performance of services under this Contract.
ARTICLE 28 .
NO THIRD-PARTY BENEFICIARIES
This Ag reement shall inure only to the benefit of the parties hereto and third persons not
privy hereto shall not , in any form or manner, be considered a third party beneficiary of
this Agreement. Each party hereto shall be solely responsible for the fulfil lment of its
own contracts or commitments.
ARTICLE 29.
MODIFICATION
No modification of this Contract shall be binding on the Contractor or the City
unless set out in writing and signed by both parties. No modification of this contract
shall be binding upon the City unless signed by the City Manager or an Assistant City
Manager of the City of Fort Worth. Any changes to the scope of work or compensation
must be in the form of a written , formal , authorized modification of this contract that is in
accordance with all applicable state and city laws , regulations , and ordinances . In no
event shall any verbal authorization changing the scope of work or verbal agreements
for additional compensation be binding upon the City. Contractor expressly agrees a)
not to make changes to its legal , financial , or logistical position on any matter based on
any oral representation by an employee , contractor , or agent of the City prior to
obtaining a written modification to this contract; b) that it waives any claim based upon
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reliance or estoppel as a result of acting or not acting due to an alleged oral change to a
material term of this contract from the City , its employees , contractors , or agents ; and c)
that it waives any claim for compensation for work performed based upon an alleged
oral change to a material term of this contract from the City , its employees , or agents .
ARTICLE 30 .
ENTIRETY
This contract , the contract documents , and any other documents incorporated by
reference herein are binding upon the parties and contain all the terms and conditions
agreed to by the City and Contractor, and no other contracts, oral or otherwise ,
regarding the subject matter of this contract or any part thereof shall have any validity or
bind any of the parties hereto. In the event of any conflict between this contract and any
other contract documents , then the terms of this contract shall govern .
ARTICLE 31 .
AUTHORITY AND EXECUTION
By signing this contract Contractor warrants that it has had the opportunity 1) to
examine this contract in its entirety , 2) to have its legal counsel examine and explain the
content , terms , requirements , and benefits of this contract if Contractor so chooses , and
3) to negotiate the terms of this contract within the bounds of applicable law .
Having had the opportunity to submit its SQQ , Work Plan , Fee Schedule , and other
contract documents , and also to specifically negotiate the terms of this contract ,
Contractor agrees to be bound by this contract and expressly agrees to the terms of this
contract.
The signatory to this contract represents that he or she is legally authorized by the
Contractor to enter into a binding agreement on behalf of the Contractor.
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ATTACHMENT A.
SCOPE OF WORK
THERE IS NO GUARANTEE OF ANY WORK UNDER THIS CONTRACT , however the
types of work which the Contractor will perform upon specific written authorization by
the City shall include the following , and related environmental and engineering
consulting services :
The Scope of Work detailed in the document entitled "City of Fort Worth Natural Gas Air
Quality Study -Final Work Plan " prepared by Eastern Research Group , Inc . and dated
August 4 , 2010 . Including the addition of Appendix B on August 6, 2010 and
incorporation of revised of Section 8.0 on August 16 , 2010.
This scope is intended to be illustrative and not exhaustive , and additional similar or
related services may be ordered subject to the terms of this contract and as authorized
by the City . In addition the city may decline to issue task orders or reduce the scope of
work described in the Work Plan at its sole discretion .
For all purposes relating to the performance bond , the Final Work Plan is agreed to be
the benchmark for determining if performance has been completed as required under
this contract , subject to duly authorized written modifications, amendments , or task
orders issued by the City .
l
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City of Fort Worth Natural Gas Air
Quality Study
Final Work Plan
Prepared for:
Mr. Brian Boerner
Director, Department of Environmental Management
City of Fort Worth
\\ERG
Easte rn Researc h G rou p, Inc .
1600 Perimeter Park Drive, Suite 200
Morrisv ille, NC 27560
Professiona l Services Contract
Air Quali Stud -Final Work Pla n
Eastern Research Grou p , Inc .
1000 Throckmorton Street
Fort Worth, Texas 76102-6311
A u gust 4, 2010
SAGE
ENVI RONMENT AL CONSULTING
Sage En viro nm en ta l Co nsul ting, LP
4611 Bee Cave s Road , Suite 100
Austin, TX 78746
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Fort Worth Natural Gas Air Quality Study Final Work Plan
CONTENTS
Section
INTRODUCTION ................................................................................................................................................ 1
1.0 TASK 1 -PROJECT MANAGEMENT ..................................................................................................... 1
2.0 TASK 2 -AMBIENT AIR MONITORING ............................................................................................... 2
3.0 TASK 3 -POINT SOURCE TESTING .................................................................................................... 12
3 .1 SURVEY NATURAL G AS EMISSION POINT SOURCES WITH THE IR CAMERA ................... 13
3 .2 CONDUCT SCREENING AT POINT SOURCES USING THE TV A .......................................... 16
3.3 COLLECT EMISSION RATE INFORMATION WITH THE HIFLOW SAMPLER ......................... 17
3.4 COLLECT SAMPLES OF voe AND METHANE USING SUMMA C ANISTERS ..................... 20
3.5 CALCULATE POINT SOURCE EMISSIONS ........................................................................ 2 1
3.6 FIELD D ATA COLLECTION ............................................................................................ 22
3.7 QUALITY ASSURANCE PROCEDURES AND EQUIPMENT .................................................. 23
3.8 PROJECT SAFETY .......................................................................................................... 25
3.9 POINT SOURCE T ESTING COSTS .................................................................................... 26
4.0 TASK 4-AIR DISPERSION MODELING ............................................................................................. 26
4 .1 MODEL SELECTION AND SCENARIOS ............................................................................. 26
4.2 MODEL INPUTS ............................................................................................................. 27
4.3 MODEL OUTPUTS ......................................................................................................... 28
4.4 MODELING HOURS AND COSTS ..................................................................................... 28
5.0 TASK 5 -COMMUNICATION AND OUTREACH ............................................................................... 28
6.0 TASK 6-FULL BUILD-OUT ESTIMATES ........................................................................................... 29
6.1 POINT SOURCE EMISSION FACTOR D EVELOPMENT ........................................................ 29
6.2 GROWTH ESTIMATE DEVELOPMENT ............................................................................. 30
6.3 EMISSIONS ESTIMATES UNDER FULL BUILD-OUT CONDITIONS ..................................... 30
6.4 FULL BUILD-OUT EVALUATION HOURS AND COSTS ..................................................... 30
7.0 TASK 7-FINAL REPORT ...................................................................................................................... 31
8.0 TIME LINE ............................................................................................................................................... 32
9.0 BUDGET ................................................................................................................................................... 34
10.0 OPTIONAL STUDIES .............................................................................................................................. 36
10.1 AMBIENT AIR MONITORING (OPTIONAL LONG-TERM STUDY) ....................................... 36
I 0.2 AMBIENT AIR MONITORING (OPTION AL WELL SITE LIFE-CYCLE STUDY) ..................... 36
10 .3 AMBIENT AIR QUALITY IMPACT OF FULL BUILD-OUT CONDITIONS (OPTIONAL) ........... 37
APPENDIX A -POINT SOURCE ANALYTICAL METHODS AND D ETECT ION LIMITS
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Fort Worth Natural Gas Air Quality Study Final Work Plan
LIST OF TABLES
Page No.
T ABLE I. T0-15 R EPORTED COMPOUNDS ................................................................................................ 3
T ABLE 2. TO-I I A REPORTED COMPOUNDS ............................................................................................. 4
TABLE 3 . SNMOC R EPORTED COMPOUNDS ............................................................................................. 4
TABLE 4. PROPOSED APPROACH AND SCHEDULE OF COLLECTION EVENTS ............................................... 7
TABLE 5. ESTIMATED COUNTS OF NATURAL GAS POINT SOURCES ......................................................... 13
TABLE 6. MINOR EMITTING COMPONENT TESTING MA TRIX ................................................................... 19
TABLE 7 . PROJECTED SCHEDULE FOR FORT WORTH NATURAL GAS AIR QUALITY STUDY ...................... 33
TABLE 8 . ESTIMATED COSTS TO PERFORM FORT WORTH NATURAL G AS AIR QUALITY STUDY ............... 34
TABLE 9. LIST OF STAFF MEMBERS FOR FORT WORTH NATURAL GAS AIR Q UALITY STUDY ................... 35
TABLE I 0 . PROPOSED APPROACH AND SCHEDULE OF COLLECT IO N E VENTS FOR THE LONG-T ERM
AMBIENT MONITORING NETWORK ELEMENT OF THE FT. WORTH SURVEY STUDY ........................ 36
LIST OF FIGURES
Figure Page No.
FIGURE I. ERG'S AIR TOXICS/SNMOC ANALYSIS LABORATORY .......................................................... 11
FIGURE 2. ERG'S CARBONYL LABORATORY AND ANALYTICAL INSTRUM ENTATION .............................. 11
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Fort Worth Natural Gas Air Quality Study Final Work Plan
INTRODUCTION
This document contains Eastern Research Group's (ERG 's) work plan for performing the
tasks and activities specified in Project DEM 10-05 (Natural Gas Air Quality Study). The
primary objectives of this project are to answer these fundamental questions:
• What quantity of emissions (on a volume and mass basis) is coming from natural
gas exploration and production sites located within the City of Fort Worth?
• Do the sites comply with applicable regulatory limits?
• What effect do emissions from natural gas exploration and production activities
have on ambient air quality at the fenceline?
• Are the City 's setbacks for wells, tanks, and compressors adequate to protect
public health?
Thi s work plan addresses each of the tasks that must be completed in order to answer the
questions above for the City of Fort Worth (the City), to ensure that the public is kept informed
throughout the duration of the project , and to prepare a final report, including findings,
conclusions, and recommendations. Under this work plan, we will implement the Ambient Air
Monitoring Network Design and Point Source Testing Plan that were developed under a separate
contract entitled "Fort Worth Natural Gas Air Quality Study Planning".
To as s ist ERG in completing this project, Sage Environmental Consulting will be leading
the point source testing task (Task 3) and providing technical peer review on all project tasks .
Also , Hicks & Company (certified by the North Central Texas Regional Certification Agency
(NCTRCA) as a Woman-Owned Business Enterprise) will be providing field sampling support.
A description of each of the project tasks is provided below in Sections 1 through 7,
Section 8 provides a project time line, and Section 9 provides budget information for each task.
Specific references to the four questions above are embedded in the discussion of each section
showing how the tasks relate to meeting the objectives of the project. Section 9 also identifies
each member of the project team and their estimated hours of participation in this project and
designates Sage and Hicks staff specifically .
1.0 TASK 1-PROJECT MANAGEMENT
This task will be used by the Project Manager (PM), the Senior Peer Reviewer, and
administrative support staff to ensure this project is executed in a technically competent manner,
in a timely fashion, and within the proposed budget ; to prepare monthly progress reports and
invoices ; and to maintain communication with the City on overall project schedule and budget.
The PM for this project is Mr. Mike Pring . In this role, he will be responsible for
directing this project 's day-to-day activities . Mr. Pring will be the central point of contact for the
City and will have overall authority and responsibility for ERG's performance on the proposed
program. He will be available to City staff on a daily basis to discuss and resolve any issues
regarding schedule, cost , or labor commitment. Mr. Pring will be available to consult with the
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Fort Worth Natural Gas Air Quality Study Final Work Plan
ERG staff and attend meetings where his knowledge and broad technical perspective on air
quality issues as related to oil and gas exploration and production will be beneficial.
Contact information for Mr. Pring is as follows:
Telephone:
Fax:
Email :
919-468-7840
919-468-7801
Mike.Pring@erg.com
The Senior Peer Reviewer for this project is Art Bedrosian of Sage Environmental
Consulting, who will provide peer review on all project tasks . Mr. Bedrosian has extensive
experience in all aspects of this project and will serve as a technical resource and in an advisory
role as the project progresses.
The cost estimate for this task is $22 ,020, based on a total project period of 8 months
(August, 2010 through March 2011). Details on the cost breakdown are provided in Table 8 .
2.0 TASK 2-AMBIENT AIR MONITORING
• What effect do emissions from natural gas exploration and production activities have
on ambient air quality at the f enceline?
• Are the City's setbacks for wells, tanks, and compressors adequate to protect public
health?
Task 2 involves the establishment of an ambient air monitoring network within the City
to quantify the concentration of volatile organic compounds (VOCs) and hazardous air pollutants
(HAPs) (such as benzene and formaldehyde) in the ambient air to assist in answering the
questions above.
Task Overview
The primary purpose for this task is to determine the prevalence and magnitude of
specific air toxics compounds in the ambient air at monitoring sites in accordance with
applicable set-backs . This data will be used to conduct a public health evaluation as described
under Task 6. As a related task, the City is interested in understanding the behavior of ambient
methane and ethane, specifically related to benzene concentration levels.
In this task , the ERG Team will use the results of the planning study to implement the air
toxics monitoring network which will be located throughout the City . During this time , we will :
I) work with the City to gain access to proposed sites; 2) distribute and review project-specific
standard operating procedures (SOPs) to field technicians to ensure consi stent sample acquisition
and handling ; 3) install certified monitoring equipment ; and 4) make adjustments to the Quality
Assurance Project Plan (QAPP) if the technical nature of the Data Quality Objectives (DQO s)
has been adjusted.
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Fort Worth Natural Gas Air Quality Study Final Work Plan
Pollutants of Inte res t
As stated in the above primary objective of this study, we are proposing sampling for
specific air toxics of:
• VOCs as identified by EPA 's method T0-15 (including benzene);
• Carbonyl compounds identified by EPA' s method TO-llA (including
formaldehyde);
• Speciated non-methane organic compounds (SNMOC), as identified by
ERG/SNMOC Analysis Method; and
• Methane , as identified by EPA 's method T0-14 .
The li st of air toxics that will be reported from these sampling methods are listed in
Table s 1-3. These three compound groups provide over 130 air toxics, including 45 hazardou s air
pollutants (HAPs), such as benzene, ethylbenzene, toluene, and xylenes (BTEX compounds),
formaldehyde , and acetaldehyde . All HAPs are denoted with a bold typeface in each of the
tables . From a toxicity standpoint, concentrations of benzene will be of primary importance for
this study .
Acetonitrile
Acetylene
tert-Amyl Methyl Ether
Benzene
Bromochloromethane
Bromodichloromethane
Bromoform
Bromomethane
1,3-Butadiene
Carbon Tetrachloride
Carbon Disulfide
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
Chloromethylbenzene
Chloroprene
D ibro moch loro methane
1,2-Di bromoethane
m-Dichlorobenzene
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Table 1. T0-15 Reported Compounds
o-Dichlorobenzene Methyl tert-Butyl Ether
p-Dichlorobenzene n-Octane
Dichlorodifluoromethane Propylene
1, 1-Dichloroethane Styrene
1,2-Dichloroethane 1,1,2,2-Tetrachloroethane
1,1-Dichloroethene Tetrachloroethylene
cis-1,2-Dichlor9eth ylene Toluene
trans-1 ,2-Dichloroethylene 1,2,4-Trichlorobenzene
Dichloromethane 1,1,1-Trichloroethane
1,2-Dichloropropane 1,1,2-Trichloroethane
cis-1,3-Dichlorop ropene Trichloroethylene
trans-1,3-Dichloropropene Trichlorofluoromethane
Dichlorotetrafluoroethane Trichlorotrifluoroethane
Ethyl Acrylate 1,2,4-Trimethy lbenzene
Ethyl tert-Butyl Ether 1,3,5-Trimethylbenzene
Ethylbenzene Vinyl Chloride
Rexach lo ro-1,3-bu tadiene m,p-Xylene
Methyl Ethyl Ketone o-Xylene
Methyl lsobutyl Ketone
Methyl Methacrylate
3
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Fort Worth Natural Gas Air Quality Study Final Work Plan
Table 2. TO-llA Reported Compounds
Acetaldehyde Crotonaldehyde Isovaleraldehyde
Acetone 2 ,5-Dimethy lbenzaldehyde Propionaldehyde
Benzaldehyde Formaldehyde Tolualdehydes
Butyraldehyde Hexaldehyde Valeraldehyde
Table 3. SNMOC Reported Compounds
n-Butane n-Heptane 2-Methylpentane
cis-2-Butene 1-Heptene 3-Methylpentane
trans-2-Butene n-Hexane n-Nonane
Cyclohexane 1-Hexene 1-Nonene
Cyclopentane cis-2-Hexene 1-0ctene
Cyclopentene trans-2-Hexene n-Pentane
n-Decane Isobutane 1-Pentene
1-Decene Isobutene/1-Butene c is-2-Pentene
m-Diethylbenzene Isopentane trans-2-Pentene
p-Diethylbenzene Isoprene a-Pinene
2,2-Dimethylbutane Isopropylbenzene ,8-Pinene
2 ,3-Dimethylbutane 2-Methyl-1-butene Propane
2 ,3-Dimethylpentane 3-Methyl-1-butene n-Propylbenzene
2 ,4-Dimethy lpentane 2-Methyl-1-pentene Propyne
n-Dodecane 4-Methyl-1-pentene n-Tridecane
1-Dodecene 2-Methyl-2-butene 1-Tridecene
Ethane Meth ylc ye lo hexane 1,2,3 -Trimethylbenzene
2-Ethyl-1-butene Methylcyclopentane 2,2 ,3-Trimethy lpentane
Ethylene 2-Methylheptane 2,2,4-Trimethylpentane
m-Ethyltoluene 3-Methylheptane 2,3,4-Trimethylpentane
o-Ethyltoluene 2-Methylhexane n-Undecane
p-Ethyltoluene 3-Methylhexane 1-Undecene
The above pollutants also include important non-HAPs that will be useful in
characterizing and differentiating between emissions from natural gas activities (such a s ethane
and other straight-chain hydrocarbons), mobile source activities (such a s tert-Amyl Methyl
Ether, acetylene, ethylene, ethyl-tert-butyl ether), other industrial processes (such a s methyl ethyl
ketone from surface coating operations or propylene from petrochemica l manufacturing source s),
and from biogenic sources (such as isoprene). Generally speaking , however, the li st of analytes is
specific to the analytical method and not to the target source type (e .g., natural gas sources and
mobile source). ·
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Fort Worth Natural Gas Air Quality Study Final Work Plan
Ambient Monitoring Network and Site Obje ctives
Prior to setting up the monitoring network, we will use the findings from work conducted
under a separate contract (Fort Worth Natural Gas Air Quality Planning Study) to identify
locations of potential monitoring sites. We will attempt to place monitoring sites as close to
applicable set-backs as possible , given logistical challenges such as accessibility to sites , security
concerns, and/or airflow obstructions such as sound blankets. Each site will be dispersed
geographically throughout the City to characterize as many natural gas sites as possible . For
example , a monitoring site located in an area of high level of natural gas activity can effectively
represent typical airshed conditions for up to a few miles , depending upon typical wind
conditions. Using that information, we can estimate a percentage of the total well pads that are
represented by the proposed monitoring network .
We are proposing setting up an air toxics monitoring network of seven sites with the
following objectives:
• Site 1: Fixed site, located in a remotely populated area to be used as a background
site (the concentrations measured at this site will be useful for comparisons and
for calculating upwind-downwind concentration differences);
• Site 2: Fixed site, located in a populated area with a moderate level of natural gas
activity conducted upwind ;
• Site 3: Fixed site, located in a populated area with a moderate level of natural gas
activity conducted upwind;
• Site 4: Fixed site, located in a populated area near a high level of mobile source
activity (this is important to differentiate potential health impacts due to mobile
sources versus natural gas sources);
• Site 5: Fixed site, located in a populated area where a high level of natural gas
activities are conducted upwind;
• Site 6: Fixed site, located in a populated area where a high level of natural gas
activities are conducted upwind ; and
• Site 7: Fixed site, to be located initially at a pre-production operation such as a
drilling , fracturing, or completion site, or at other areas of interest. This site may
be relocated during the course of the project to a site in various stages of pre-
production.
This type of network design has been utilized in our work for many of our Agency for
Toxic Substances and Disease Registry's (ATSDR) exposure investigations , which included two
studies characterizing ambient air impacts from oil and natural gas wells. Using the above
network design (up to five sites dedicated to characterizing ambient air from natural gas
activities , a remote background site, and a site close to mobile source activity), we are confident
that we will be able to evaluate the impacts of natural gas activity as close to the setbacks as
possible in a scientifically defensible manner.
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Sampling Frequency
During this st udy, ERG is propo si ng sampling every 1 in 3 day s at each of these s it es.
Over the course of two months , this s hort-term sampling sc hedule will yield approxim ately
20 sa mpling days, which we believe is a sufficient number of data point s to calculate an est im ate
of long-term concentrations for a number of air toxics. Thi s type of "s hort-term" average is
currently being used by EPA in their evaluation of monitoring data for the School s Air Toxic s
Initiative . These estimates will then be compared to various public health exposure leve ls to
assist in determining whether or not we recommend that monitoring be extended to an annual
period .
Each sa mple conducted will be 24-hour sa mple s targeting VOCs and SNMOC. Specific
monitoring at the sites will be:
I) Three fixed sites collecting integrated 24-hour whole air sa mples for co ncurrent
analysis resolving T0-15 and SNMOC target compounds. These sites would use
the Veriflow collection technology and not require sheltering or 1 lOvAC power.
Collection frequency is l-in-3 days for every site.
2) Two fixed sites collecting integrated 24-hour whole air sa mple s for concurrent
analysis resolving T0-15 and SNMOC target compounds and integrated 24-hour
whole air samples for TO-I IA target compounds. All duplicate collections for
A.T./SNMOC and Carbonyls would be conducted at these s ites also. These s ite s
would use conventional collection technology and would require sheltering,
temperature control, and 11 OvAC electric power. Collection frequency is l-in-3
days for every site.
3) Two fixed sites collecting integrated 24-hour whole air samples for Methane and
air toxics analyses. The se sites would use the Veriflow collection technology a nd
not require sheltering or 11 OvAC power. Collection frequency is l-in-3 day s for
every site .
Table 4 presents the sampling sc hedule.
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Table 4. Proposed Approach and Schedule of Collection Events
Concurrent A.T./SNMOC Carbonyl
A.T./SNMOC Carbonyl Duplicate Duplicate Methane and
Date Collection Collection Samples Samples A.T. Samples
8-17 -----8-20 ----
8-23 ----
8-26 From 2 Sites From 2 Sites
8-29 ----
9-01 ----
9-04 ----
9-07
From 5 Fixed From 2 Fixed From 2 Sites From 2 Sites
From 2 Fixed 9-10 Sites ----
9-13 Sites Sites ----
9-16 (Site Numbers (Site ----(Site Numbers
9-19 1-5) Numbers 4-5) From 2 Sites From 2 Sites 6-7)
9-22 ----
9-25 ----
9-28 ----
10-01 From 2 Sites From 2 Sites
10-04 ----
10-07 ----
10 -10 ----
10-13 From 2 Sites From 2 Sites
/
Sub-Total Sub-Total Sub-Total Sub-Total Subt otal
Samples= Samples= 40 Samples= 10 Samples= 10 Samples= 40
10 0
Overall Total Samples= 200
Pre -Fie ld Operations
In this section , ERG describes pre-field activities which will occur prior to samp lin g
initiation, which include:
1) ERG wi ll check-out, certify (as required), calibrate (as required), all equipment
that will be deployed to the fie ld.
2) ERG will ship the field collection systems to the field for deployment ,
approximate ly. 9 days prior to the first sched uled sampling event. This shipment
will include everything required to assemble and install the 7 sample collection
s ystems . This would include a ll system components, anci ll ary materials (i.e.,
fittings , stain less steel tubing , timers , chargers , etc .), associated Standard
Operating Procedures, and too ls . The only materials/items envisioned for
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purchase in the field would be those that are required do to specific site
considerations after site inspections have been performed .
3) ERG will travel to study location and in stall and check-out the sample collection
syste ms at each site approximately 7 days prior to the first sc hedul ed collection
event.
4) ERG will train all field staff in the proper operation of the five Timer/V eriflow
collection systems and the two Canister/Carbonyl collection systems, and the
required procedure for collecting valid repre se ntative sa mples us ing the se
systems.
5) ERG will train field staff in the proper procedure s for receiving , handling , and
shipping sa mples media.
6 ) ERG will travel to study location and install and rec'over the sample collection
sys tems at each site approximately 3 day s after the la st sc heduled collection
event, and ship this equipment back to the ERG Laboratory.
7 ) Upon receipt, ERG will repair/refurbish all field equipment as req uired.
Field Operations
In this sec tion , ERG de sc ribes field activities which will occur as part of normal sa mpl e
pre-collection procedures and operations associated with collecting Air Toxics VOC and
Carbonyl Compounds samples on a l-in-3 day frequency.
I) Approximately I week prior to each sc heduled collection event, the field operator
will receive via Federal Express a shipment of prepared media (i.e., cleaned
evacuated 6-L SUMMA canisters and or DNPH Carbonyl tubes) in quantities
consistent with conducting an entire weeks worth of field sa mple collections. The
DNPH Carbonyl tubes will be shipped in a cooler with blue ice. They will be
placed in a refrigerator at the common stag ing area until ready for use collecting
field sa mples . The blue ice will be placed in a freezer until ready for re-use
shipping the samples back to the laboratory . Along with the media, specific
associated multi-copy Chain-of-Custody (COC) forms will be provided . The COC
forms will already have all laboratory origination information completed on them.
2) Two day s prior to each sc heduled sampling event, for the canister collection
systems that are battery powered , the operator will charge the digital control
timers using the transformers provided for each system. The charging will occur
at the common staging location.
3) One day prior to each collection event, a field operator will visit each s ite to
perform the following:
a. Carefully transport and deploy each of the battery operated cani ster
collection systems (at location s where fixed syste m s are not deployed);
b. Install new collection media (i.e ., cleaned evacuated 6-L SUMMA canister
for battery operated site s and cleaned evac uat ed 6-L SUMMA canisters
and DNPH Carbonyl tubes for fixed sys tem s it es);
c . Program the digital timer to initiate sampling at 00:01 and terminate
sampling at 11 :59on the date of the sc heduled event;
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d. Enable collection for each media type (e.g., open canister bellow s valve);
and
e. Complete all associated paper work including completion of pre-collection
COC information (e.g., document initial canister pressure , document
initial DNPH carbonyl tube collection flow rate, etc.) and site log book
entries.
Post-co ll ection Field Operations
In this sectio n, ERG describe s field activities which will occur as part of norma l sample
po st-co llection procedures and operations associated with collecting Air Toxics VOC and
Carbonyl Compounds samples on a l-in-3 day frequency.
1) One day after each collection event, a field operator will visit each s ite to perform
the following:
a. In spect the site for anything unu s ual (e.g ., damaged/broken equipment,
vandalism, evidence of tampering, etc.). If problems are noted , the
operator will immediately contact the ERG Project Manager and the
pertinent City staff to report the problems. At that time, a corrective action
may occur (i.e., resample, relocating the equipment, etc.). If no problems
are observed, then proceed to the next step;
b . Disable collection for each media type (e.g., close canister bellows valve,
ensure that each canister inlet valve port is capped);
c. Complete all associated paper work including completion of post-
collection COC information (e.g., document final canister pressure,
document final DNPH carbonyl tube collection flow rate , document
elapsed time, etc .) and site log book entries. If final canister pressure
and/or flow rate do not meet the method criteria, then the operator will
notify the ERG Project Manager immediately. If possible, a make-up
sample may be taken immediately. If there are no problems with the
sample collection, proceed to the next step;
d . Recover collection media (i.e., whole air canister samples for battery
operated sites and whole air canister and DNPH Carbonyl samples for
fixed system sites).
2) Carefully transport each of the battery operated cani ster collection systems (from
locations were fixed systems are not deployed) and recovered sample media back
to the common staging area.
3) Place the DNPH Carbonyl sa mples in the refrigerator at the common staging area
until they are ready to be shipped back to the laboratory for analysis.
At this point step s the operator is ready to begin the Pre-collection steps in preparation
for the next collection event.
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Sample Shipping
In this section, ERG describes sample shipping ac tivities which will occur as part of
normal sample post-collection procedures and operations associated with collecting Air Toxics
VOC and Carbonyl Compounds samples on a 1-in-3 da y' frequency .
1) One day after each sample collection, place a canister sample and its associated
COC inside of the large bubble bag provided with each canister. Place the bagged
canister in s ide the shipping box provided with each canister. Secure the shipping
box with the packing tape provided .
2) Place one events worth of DNPH Carbonyl samples in a zip lock baggie . Place
their associated COCs in another zip lock baggie. Place the two baggies in the
small cooler as provided . Place blue ice in the cooler as provided.
3) Complete a Federal Express (FedEx) preprinted bill of laden (i.e., over night
service) for each canister sample shipping box and each DNPH Carbonyl samples
cooler prepared for shipment. Secure the bill of laden to each parcel.
4) Have parcels picked up by FedEx, or deliver the parcels to FedEx, for overnight
shipment the same day that they are prepared .
Sample Handling , Tracking, Analysis, and Reporting
In this section, ERG describes laboratory activities which will occur as part of norm a l
sample handling, tracking, analysis, and reporting Air Toxics VOC and Carbonyl Compounds
samples.
1) The day after they are shipped from the field, samples will be delivered to the
loading dock at ERG's laboratory complex. A dedicated receiving s pecialist will
take custody of the parcels. Each sample will be inspected to ensure that it arrived
intact and to establish that the validity of the sample was not compromised in any
way during shipment.
2) The receiving specialist will complete all associated paper work including as
received COC information (e.g., document as received canister pressure, calculate
and document DNPH carbonyl sample total collection volume, etc .) and receiving
log book entries.
3) The receiving specialist will then log each sample into ERG's state-of-the-art
Laboratory Information Management System (LIMS). During sample login, each
sample will receive the following (this information allows the sample to be
tracked and status-checked throughout all laboratory process):
a. A unique sample identification number ;
b. A batching descriptor specifying specifically what analyses the sa mple is
to undergo and data turn-around time requirements.
4) Air Toxics samples will be prepared and analyzed in strict accordance with the
guidelines presented in EPA Compendium Method T0-15 and the EPA NATTS
Technical Assistance Document (TAD). Speciated Nonmethane Organic
Compounds analyses will be performed in accordance with the guidelines
presented in the EPA Carbon Bond 4 Method and the EPA Ozone Precursors
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Sampling and Analys is TAD. Carbonyl Compounds will be analyzed in strict
accordance with the guidelines presented in EPA Compendium Method T0-1 lA
and the EPA Ozone Precursors Sampling and Analysis TAD. Figures 1 and 2
present ERG 's Air Toxics/SNMOC laboratory and ERG's carbonyl laboratory .
Figure 1. ERG's Air Toxics/SNMOC Analysis Laboratory
.......
~··'i':
Figure 2. ERG's Carbonyl Laboratory and Analytical Instrumentation
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5) Raw data is transmitted electronically from each analytical system directly to
ERG's LIMS. Within LIMS, the raw analytical data is converted into quantitated
measurement values.
6) ERG employs a robust multi-check, multi-level data review process to ensure that
all data generated is valid and representative.
7) Data is generated in a form that is easily imported into spreadsheets (e.g .
Microsoft Excel) or database management programs (e.g . Microsoft Access or
SQL).
8) Data quality will be assessed as follows:
a. Precision will be assessed by analyzing collocated samples from the fixed
monitoring sites in replicate (i.e., nested). The CV provides a relative
measure of variability by expressing standard deviations to the magnitude
of the arithmetic mean. The lower the CV, the less likelihood that
analytical results would vary due to sampling error.
b. Bias will be assessed by analyzing blind performance evaluation (PE)
samples as provided by EPA as part of the National Monitoring Programs.
Bias will be expressed in terms of relative percent difference (RPO). ERG
regularly receives these blind PE samples from EPA and the associated
performance data provided by EPA will be made available for this study.
The cost estimate for this task is $228 ,071. Details on the cost breakdown are provided in
Table 8.
3.0
•
TASK 3 -POINT SOURCE TESTING
What quantity of emissions ( qn a volume and mass basis) is coming from natural gas
exploration and production sites located within the City of Fort Worth?
The focus of this task is to characterize hydrocarbon emissions from natural gas point
sources located within the boundaries of the City. We propose to do this through a detailed and
near comprehensive point sources testing plan as explained below . While surveying all 600+
point source locations (wells, well pads, compressor stations , and treatment and disposal
facilities) would be desirable, it may not be feasible given time and resource constraints .
However, our plan (outlined below) attempts to survey, at a minimum, 75 % of the existing point
sources. We also understand that the City would like to have this testing conducted in the late
summer to early fall months when elevated ambient temperatures can be expected.
To accomplish this, we propose to deploy two point source teams, each fully equipped
with the necessary sampling instrumentation . Specifically, we will perform the following sub-
tasks :
1) Survey, at a minimum, 75% of the existing natural gas emission point sources with
the FLIR infrared (IR) camera;
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2) Conduct scree ning with a Thermo Environmental TV A 1000B analyzer on a subset of
point so urce components at each location following the procedures of EPA Method
21 1;
3) Perform on-site emission rate testing at each location using the Bacharach High-
Flow® Sampler ;
4) Collect samples of emissions at select locations for VOC and Methane analysis in
evacuated Summa™ canisters to determine compound specific emission rates;
5) Calculate point source emissions;
6) Field Data Collection; and
7) Quality assurance.
At the conclusion of this task, we will prepare draft and final reports to the City
summarizing the point source testing results, as well provide all information used to generate
emissions (spreadsheets, video footage , equipment characteristics, etc.).
3.1 Survey Natural Gas Emission Point Sources with the IR Camera
The objective of this sub-task is to survey point source equipment at natural gas facilities.
We will use the IR camera to survey:
• Active well pads ;
• Compressor stations;
• Processing facilities;
• Tank batteries;
• Saltwater evaporation facilities;
• Water recycling units; and
• Gathering stations under City control.
Natural gas transmission lines will not be included in the point source survey unless
located within the battery limits of any of the above facilities. While the exact number of point
sources within the City is currently unknown until the results of the planning contract are
finished, we are presenting approximate counts in Table 5:
Table 5. Estimated Counts of Natural Gas Point Sources
Point Source Type Estimated Count
Well Pads -645
Compressor Stations -20
Process ing facility 1
Tank batteries Estimated number unavailable
Saltwater treatment facility 1
Water recycling units 2
1 Federal Reg ister.Vol. 65, No. 201.Tuesday, October 17 , 2000. Rules and Regul ation s. Method 21-Determination
of Volatile Organic Compound Leaks
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As stated before , ideally we would like to capture all natural gas facilities within the City.
However, this goal may not be feasible due to cost and time constraints . Therefore , we are
proposing to survey, at a minimum, 75 % of the natural gas facilities, randomly selected from the
entire population of facilities. The exact number will be determined once the results of the
planning study are completed. We feel that information gathered from a minimum of 75 % of the
natural gas facilities will provide a wealth of information in characterizing emissions from these
sources. Additionally , scientifically defensible and statistically robust surrogates can be
developed and applied to the facilities which were not surveyed . To ensure as representative
coverage as possible, the City will be gridded into equal area sections with an alphanumeric
identifier applied to each section. Individual Sector Survey maps of the sources of interest will be
created from the GIS information provided by the City, and assigned to each Point Source
Sampling Team. The two survey teams will work in adjacent sectors to facilitate
communications, to provide each other with equipment and manpower support as necessary , and
for safety reasons.
Equipment surveys will be performed by Level I and Level II Thermographers using
FUR GasFindIR® cameras . An example camera is presented below.
Ga ~Fln dlR cam Qra
All emissions detected with the IR camera will be video recorded. Emission points will
also be photographed with a digital camera to aid with identification . The advantage of using the
IR camera is that it is able to scan large areas rapidly and visually detect emissions (i .e ., large
emissions greater than I 0,000 ppmv) in real time. It is ideal for sensing emissions from
equipment in natural gas service since it readily responds to methane, the largest constituent of
natural gas , as well as ethane, propane, and butane. Another advantage of the IR camera is that
the operator can effectively use this technology at a distance up to 50 feet from the source of
interest.
While the IR camera is extremely good at detecting large emissions , it is limited in
several important aspects :
• It does not reliably detect "minor" emissions (i .e. emissions that are less than
10 ,000 ppmv).
• It cannot quantify ;:in emission's concentration in ppmv .
• It can not provide empirical data on the emission's mass release rate -how many
pounds per year are being emitted?
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• It cannot speciate the emissions. It is unable to tell, for instance , how much of the
emission is methane, propane, ethane, benzene, or xylene.
The following information will be collected at each site:
• Well pad Name/ID ;
• Owner/operator information;
• Physical location information (address, GPS coordinates, facility boundaries);
• Information on activities taking place during the point source testing (i.e., drilling,
•
•
•
•
•
fracturing, completion, production, etc.);
Description of equipment at site/digital photograph;
Facility Throughput ( cf/d);
Wet gas/dry gas information;
Site operational status; and
Valve , connector and other components counts .
Additionally, the following information will be collected at each site for each IR-detected
emission point:
• Timestamp ;
• Equipment ID/Description;
• Equipment Size;
• Camera ID/Operator ID;
• Detection Distance (feet);
• Screening Value (ppm);
• Video File Name;
• Ambient temperature (°F), wind information, relative humidity(%); barometric
pressure (kPa), and cloud cover(%) using a hand-held device;
• Ambient lighting;
• IR background ; and
• Maximum siting distance.
Finally, the following modeling information will be collected from the owner and/or
operator when emissions are detected with the IR camera:
• Vents or Stack Information -release height (ft) above ground, gas temperature,
gas velocity (ft/sec), stack diameter ;
• Fugitive fixed point releases -release height above ground;
• Area sources information -release height above ground, geometry, width (ft),
length (ft);
• Tanks information -Roof height above ground (ft), Tank diameter (ft); and
• Nearby traffic conditions.
If a site has compressor engines, we propose to collect engine operating parameters (e.g.
engine make, model, and size) and contact the equipment manufacturer to obtain emission
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factors (e.g., NO x, PM , hazardous air pollutants , etc). In lieu of vendor data, U.S . EPA published
emission factors may be used to estimate emissions.
3.2 Conduct Screening at Point Sources using the TV A
The objectives of this sub-task is to screen all emissions from sources identified by the IR
camera, as well as to screen a subset of components from which no emissions were detected with
the camera . This task will be conducted at each site. Assuming that the points of interest are
accesible, screening will be performed with a Toxic Vapor Analyzer (TVA) 1000B following the
procedures of U.S. EPA Method 21. An example TVA IOOOB is presented below.
TVA 1000&
The TV A-1 OOOB is a portable hydrocarbon monitor with a screening range extending
from 0 .5 ppmv to 50,000 ppmv . Because it is portable , operators can take measurement s as close
to the equipment as possible . However, we do anticipate that at some s ites, us ing this technology
may not be po ss ible due to the locations of the sources of interest.
The analyzer uses a flame ionization detector (FID) to sample and measure gases .
Concentrations in ppmv can be read on both the hand held probe and on the instrument s idep ac k .
The response of the TV A to different hydrocarbons is determined by the response characteristics
of the flame ionization detector and by the gas species used to calibrate the instrument. The unit
is factory calibrated with methane. Since methane is the large st constituent of natural gas ,
continued methane-calibration of the TV A is appropriate for this project. Thus all concentrations
detected by the TV A I OOOB will be reported as methane.
Equipment Testing
All emissions that are detected by the IR Camera will be further screened with the TV A
to measure their concentration in parts per million volume (ppmv). Because the camera sees
large emissions (i.e . > 10,000 ppmv), the concentration of so me emission point s will likely
exceed the upper range of the TV A (50,000 ppmv or 5 %) re sulting in a po ss ible "flam e-o ut " of
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the analyzer.2 In these instances, we will employ a common practice of using a 10 : 1 dilution
probe to dilute the sample to a concentration level that is able to be surveyed using the TV A (the
sample will be diluted to below 50 ,000 ppmv).
Components Testing
Becau se a typical wellpad may contain hundreds to thousands of components, it is not
feasible from a time perspective to test each component. We will attempt to screen as many
components as possible , but given the typical duration of a site visit, we anticipate that , at an
average screening rate of 250 components per hour, a minimum of 10 % of the total number of
facility components will be screened us ing the TV A, including all sources identified by the IR
Camera. Minor-emitting components (those not detected using the IR Camera but detected using
the TVA) will be randomly selected from the following component types: Valves, Connectors,
and Other Components (pumps, compressors, pressure relief devices, open ended lines ,
pipelines, etc.).
3.3 Collect Emission Rate Information with the HiFlow Sampler
The objective of this sub-task is to measure emission rates from equipment directly with
the Bacharach HiFlow Sampler. This information is important in accurately estimating emission
rates at each point source being surveyed. The HiFlow Sampler is a portable , intrinsically safe
in strument designed to determine the rate of gas leakage from components in natural gas service.
An example of this equipment is presented below.
GAS SAMPLE !Nt..ET SCREEN
! C.j,. -.,..__
HIGH,HO SAMPLER
SOU.NOI0',/#,1.'/E.
u..n»neofl~PQ'fM.lrno,,
f'lcf~--h.0.11:ih ~a..~~
Ol"lllpal,,.la'lil
LO'./JPH.ESSURf.
S>J,lf'UNGPOiNT
A component 's leak rate is measured by sampling at a high enough flow rate to ensure
that all of the gas emitted from the component will be captured. The HiFlow Sampler calculates
the resulting leak rate as % concentration per cubic feet/minute by accurately measuring the flow
rate of the sa mple stream and the natural gas concentration within that stream. Emissions from a
component are drawn into the unit through a flexible 1.5 inch I.D. hose. An assortment of hose -
2 A TV A flame-out can occur when the sa mpl e concentration is s uffici ently hi gh to prevent s ufficient air from
reaching the detector burner assembly. As a res ult the h yd r ogen flame is extin g uished a nd the analyzer mu s t be r e-
lit.
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end attachments are availabe to provide a means of capturing all the gas that is being emitted .
Sample flow rate is meas ured as the pres s ure differential developed as it passes through a fixed
orifice and sa mple concentration, as methane, is measured by an on-board combustible gas
se nso r with a range of 0.05 % (500 ppm) to 100% gas by volume .
The HiFlow Sampler will be used to test the flow of emissions from so urce s that have
been identified by the IR Camera. Since each Sampler run only takes 3-8 minutes , this pro vides
a very quick and economical way to measure emission rates from the se so urce s. The same
constraints applicable to the screening of components with the TV A, will apply to testing with
the HiFlow Sampler. That is, components considered Difficult to Monitor or Unsafe to Monitor,
will not be able to be tested with the HiFlow Sampler. Instead, they will be docume nted and the
li st provided to the City for consideration.
The HiFlow Sampler will also be used to determine emission rates for coT11ponents
identified through the screening effort with the TV A to have emission concentrations greater
than 500 ppmv.
Minor-Emitting Component Testing
As stated above, we will randomly collect TVA sa mples from minor-emitting
components. To generate emission rates for these minor-emitting components, we will also us
the HiFlow Sampler to characterize emission rate flows. While one inspector is surveying the
facility with the IR camera, the second inspector will conduct a se lective screening of
components with the TV A following EPA Method 21 procedures. The purpo se of this sc reenin g
will be to identify equipment emissions that are below the detection threshold of the IR camera
(i .e. minor emissions< 10,000 ppmv). Since the cumulative effect of these minor emission
so urce s can possibly equal or exceed a major source emission, it is important that they be
considered in a facility's overall emission potential.
Two types of "units" will be considered in this case: natural gas facilities in wet
gas serv ice and natural gas facilities in dry gas se rvice. Since components with emission
concentrations of 10,000 ppmv and above (i.e . components with emissions sufficient to
be d etected by the IR camera) will have a lready been selected for emission rate te st in g,
additional emis s ion rate testing would only need to be conducted in the three categories
below 10,000 ppmv. Since the HiFlow Sampler cannot reliably detect emission rates at
concentrations less than 500 ppmv, we propose to conduct HiFlow S a mpler emission rate
te st ing on components falling within the following two concentration groupings: 500-
1000 ppmv and 1001-10,000 ppmv and to use EPA emission factors for components
with emission concentrations below 500 ppmv.
Table 6 defines the proposed HiFlow Sampler test matrix for components with
scree ning values between 500 -10 ,000 ppmv.
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Table 6. Minor Emitting Component Testing Matrix
Screen in g Componen t Service Concentration
(pp mv) Type
1-500 All
Val ve
500-1000 Connector
Other
Valve
1001-10 ,000 Connector
Dry Gas Other
1-500 All
Valve
500-1000 Connector
Other
Valve
1001-10 ,000 Connector
Other
All
1-500
Valve
500-1000 Connector
Other
Valve
1001-10 ,000 Connector
Wet Gas Other
1-500 All
Valve
500-1000 Connector
Other
Val ve
1001-10 ,000 Connector
Other
Tota l HiFlow Sampler Tests of Minor Emittors
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Stream # HiFlow
Sampl e r Ph ase Tests
EPA
Emi ss ion
Factors
6
Gas 6
6
6
6
6 I
EPA
Emi ss ion
Factors
Light 6
6 Liquid 6
6
6
6
EPA
Emi ss ion
Factors
6
Gas 6
6
6
6
6
EPA
Emi ss ion
Factors
Light 6
6 Liquid 6
6
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The emission rates developed for each of these service-component type combinations
will be used to generate equipment count-service type surrogate factors, which can then be
applied to the enitre natural gas inventory. ·
The following information will be collected when emission rate measurements are made
using the HiFlow sampler:
• Equipment ID/Description;
• Equipment Size;
• Operator ID;
• Pre-Screening Value (ppm);
• HiFlow Sampler ID;
• HiFlow Sampler Sample ID ;
• HiFlow Sampler Result(% * cfm); and
• Post-Screening Value (ppm).
3.4 Collect Samples of VOC and Methane Using SUMMA Canisters
The objective of this sub-task is to determine compound-specific emission rates by
collecting VOC and methane samples using SUMMA canisters. Although ideal, it is not
economically feasible to collect this data at each site. Therefore, collection of these samples will
be taken at a representative number of point sources, which then can be used as surrogates for the
entire population. An example of a SUMMA canister is presented below.
SUMMA
Canister
The canister samples will be collected at the exhaust port of the HiFlow Sampler and se nt
to TestAmerica laboratories in Austin, Texas for general hydrocarbon analyses (Analytical
Method T0-15), and for methane analyses (Analytical Method D-1946). Information about these
two analytical methods is provided in Appendix A.
Because emission rate data from the HiFlow Sampler is basically expressed as % total
hydrocarbon per cubic foot/minute (i.e., methane respon se factors), we will be able to u se the
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results of the Summa canister analysis to determine the emission rate for individual compounds,
such as benzene, toluene, methane , ethane, propane, butane, etc.
For typical sampling scenarios , it is expected that no more than one canister sample will
need be collected to characterize multiple IR-detected emissions at any one facility. The reason
is that once the emis s ion rate as methane has been measured with the HiFlow Sampler, the same
constituent proportions identified in a single canister sample can be assumed for all emission
sources at that s ame facility. In other words , if three IR-detected emissions are identified at the
same facility, the emission rate for each will be determined with the HiFlow Sampler but only
one canister sample will be collected and used to calculate speciated emission rates for all three.
Atypical sampling scenarios occur if the speciation profile of additional sources is expected to be
different from the majority of sources. For example, sites with saltwater tanks may have a toxics
speciation profile that is different, thus requiring multiple canister sampling.
Speciated emission rates will be reported in pounds per hour, unless other units are
requested.
The following information will be collected when VOC and methane samples are
collected :
• Canister ID#;
• Canister Sample Number;
• Canister Initial Vacuum (inch-Hg);
• Canister Sample Start Time (HH:MM:SEC);
• Canister Sample Stop Time (HH:MM :SEC); and
• Canister Final Vaccuum (inch-Hg).
In addition to the canisters that will be sent for laboratory analysis, the City is also
interested in collecting additional canister samples, but not analyzing them immediately or at all.
The idea is that if more speciated canister sampling data is needed to enhance the surrogate
profiles , the City can have the option of having these canisters analyzed without having to go
back to a site. For these canisters, we will follow the same procedures in collecting the sample
mentioned above.
3.5 Calculate Point Source Emissions
The objective of this sub-task is to calculate point source emissions. We will generate
emission rates for each unit/component surveyed using standard equations. For example, if the
HiFlow sampler detects a 5 % methane emission at a flow rate of 8 cubic feet/minute, and an
analysis of a canister sample collected at the exhaust of the HiFlow sampler yields a 50 ppmv
benzene concentration, then the benzene emission rate can be calculated as:
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C X ¥/Ml
E.R. = 24.4s x FR x 7.7E-7
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Where:
E.R. = Emission Rate (lb/hour)
C = Concentration (ppmv)
MW = Molecular Weight
24.45 = Molar Volume@ 25°C and l atmosphere
FR = Flow Rate (ft3 /min)
7.7 E-7 = Units Conversion Factor.
In the above example, a 50 ppmv benzene canister concentration measured at a flow rate
of 8 ft3/min would correspond to a benzene emission rate of 9.84 E-4 lb/hour, using 78.11 g/mol
as the molecular weight of benzene.
Emission points < 500 ppmv are outside the range of the HiFlow Sampler, but can be
characterized using EPA screening correlations. Using these correlations, we can determine
emission rates for components with concentrations below this threshold. Alternatively, if the City
desire s to quantify emission rates below 500 ppmv using the site-specific test data, the
blow-through bagging method as described in EPA's Protocol for Equipment Leak Emission
Estimates3 can be performed as an option. The speciation profiles developed from the canister
data will still be applied to these low concentration data.
Based upon previous experience at other natural gas sites, it is expected that a sufficient
number of minor emitting components in both dry gas and in wet gas service will be avalable for
testing to provide an good understanding of the contribution of s maller emissions ( <10,000
ppmv) to a facility's overall emission profile. This information will also be valuable in
determining emission increases due to future buildup.
3.6 Field Data Collection
Due to the size and nature of this study, it will be important that all data is collected
during each site visit, and archived properly. Site specific information will be collected at eac h
point so urce location and recorded digitally on Archer Field PCs . An example field PC is
pre se nted below.
3 United States Environmental Protecti on Agency. Protocol for Equipment Leak Emission Estimates. EPA-453/R-
95-0 17. November 1995 .
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This information will include site characterization data, IR-detected emission data,
emission rate testing data and information necessary to the modeling effort. Pre-formatted
electronic datasheets stored on the Archer Field PCs will be used to record site information and
monitoring results. At the conclusion of each day's point source testing, data stored on the Field
PCs will be downloaded to spreadsheets and backed up on dedicated hard drives.
All emissions detected with the IR Camera will be video recorded and saved as digital
video files . These video files will subsequently be processed using Windows Movie Maker™
software. Processing of raw video files will consist of adding a title slide with timestamp and
descriptive information followed by a digital photograph of the emission source. Some editing of
the IR Camera video may be performed to improve quality of presentation. The completed video
recording will then be saved with a descriptive filename as a Windows Media Video file
(*.wmv).
3.7 Quality Assurance Procedures and Equipment
The objective of this sub-task is to ensure that all procdures are followed and all testing
equipment is working properly. Below , we list the responsibilities of the quality
assurance/quality control (QA/QC) reviewer and equipment calibration procedures.
QA/QC Reviewer
Mr. Arthur Bedrosian will serve as Quality Control reviewer of the point-source survey
effort. With nearly 40 years of experience , Mr. Be9rosian has worked on numerous air quality
projects within the state of Texas , and has keen insight and sensitivity to all facets of point
sources testing. Mr. Bedrosian' s responsibilities will include the following:
• Oversight of the survey program for conformance with this work plan, any
relevent standards and instructions;
• Checking identification and completeness of project documentation;
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• Checking for appropriate u se of forms, Jogs or formats;
• Ensuring that all equipment is properly referenced and calibrated;
• Checking that equipment meets specifications; and
• Random inspection of field activities to ensure they are being performed in
accordance with the procedures listed in this project plan and that in strument
calibration records are complete and indicate that instruments are in a state of
control during use.
Mr. Bedrosian will report any quality control concerns to the Point Source Project
Manager, Mr. David Ranum who will be responsible for addressing them.
In strument Calibration
Individual quality assurance items for each piece of equipment include , but are not
limited to the following:
1. IR Camera Daily Demonstration . The following procedures will be implemented each
day prior to using each IR camera for emission surveying:
a. The camera will be turned on and allowed to cool down (cool down time is
approximately 6 minutes);
b. Following cool down, the camera will be taken outside and allowed several
minutes to equilibrate to ambient conditions ;
c. After the equilibration period, several non-uniformity corrections will be
performed; and
d. The camera daily demo (dai ly demonstration) will then be conducted. This
demonstration will be performed at two mass flow rates: a low rate equivalent to
approximately 5 grams propane/hour and a high rate equ iv alent to approximate ly
25 grams propane/hour, with a video recording made of each result. The distance
from which the camera operator is able to see the propane plume (i.e., the sighting
distance) will be recorded for each mass flow rate together with ambient
temperature, wind speed, relative humidity, barometric pressure, cloud cover, and
ambient lighting conditions.
2 . TVA 1000B Calibration and Drift Checks. The TVA IOOOB™ analyzers will be
calibrated daily prior to field use with certified ±2 % accurate calibration gases
equipped with demand-flow regulators. Both instruments will also be performance
tested (response time, precision, flow rate) at the start of the testing period. Four gas
standard concentrations will be used for the daily calibrations: 0, 500, 1,000, and
10,000 ppmv methane-in-air. Drift checks will be performed using the 500-ppmv
standard, at mid-day and at end-of-day. Calibration and drift check acceptance criteria
will be ±10% of each calibration gas certified concentration . Any responses outside
the acceptance criteria will require either re-calibration or trouble shooting and repair
of the analyzer.
3 . HiFlow Sampler Calibration. Both HiFlow Samplers will be calibrated each day prior
to use. For calibration of the background sensor, a 2.5 % methane standard will be
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used. To calibrate the Gas Sample sensor, a I 00% methane s tandard will be used.
Both gas standards will be equipped with Demand Flow Regulators.
4. Cani ster Sample Collection OC Procedures . The vac uum of each canister will be
checked and documented prior to sampling . Canisters with a vacuum of< 25 in.
mercury (Hg) will not be u sed. A res idual vacuum of 5 -10 in. Hg will be left in the
canister following sample collection. This value will be documented. Appropriate
chain-of-custody procedures will be followed for all canister samples. This means
keeping an accurate written record to track the possession , handling , and location of
the canisters from collection through analysis. Canisters in possession of the point
source survey team will be kept in a secure area with access restricted to authorized
perso nnel only. The following chain-of-custody guidelines will be observed:
a . Only perso ns associated with the project will be allowed to handle the canisters.
b. Strict documentation of the transfer of canisters and data from person to perso n
will be kept on chain-of-custody forms.
c. Written canister documentation will always be legible and with permanent ink.
d. Canister serial numbers will be recorded on the chain of custody documentation.
While Field, Trip and Ambient blanks are customary in ambient air canister sampling
they are less of a consideration in point source sampling due to the high
concentrations involved. No canister blanks are planned for the point source sampling
effort. Field duplicates are second samples collected in the field simultaneously or
near-simultaneously with the primary sample at the same location. The results of the
duplicate sa mple may be compared with the primary sample to provide information
on consistency and reproducibility of field sampling procedures . Field duplicates will
be co llected at a 5 % rate (i.e . 1 duplicate per 20 canister samples).
5. Analytical OC Procedures. Analytical QC procedures will include the following:
a. Defining in-house control limits for s urrogates, matrix s pikes and laboratory
control samples .
b. Batch method blank analyses.
c. Analysis of Quality Control Samples .
d. Canister blank checks.
e. Laboratory control sample and control sample duplicates.
f. Sample duplicates .
g . Surrogate sample analyses.
h. Internal standards analyses .
1. Instrument performance checks.
3.8 Project Safety
Project safety is important to the City, to the Contractor, and especially to the point
so urce team members. A project Safety & Health plan will be drafted specific to this project.
Each project team will be required:
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a. To keep with them a signed copy of the project safety plan.
b. To hold daily safety toolbox meetings to review specific project hazards either
encountered or anticipated.
c. To have readily available an emergency first aid kit.
d. To have all required PPE as specified in the project safety plan.
3.9 Point Source Testing Costs
4.0
•
•
The cost estimate to complete this task is $246,477. Details are provided in Table 8 .
TASK 4-AIR DISPERSION MODELING
What effect do emissions from natural gas exploration and production activities have
on ambient air quality at the f enceline?
Are the City's setbacks for wells, tanks, and compressors adequate to protect public
health?
Using the point source emissions data obtained under Task 3 , air dispersion modeling
will be performed to determine the effect that natural exploration and production activities have
on ambient air quality. Established air quality models will be used to determine pollutant
concentrations at facility fencelines, as well as at distances required under the City 's setback
provisions contained in Ordinance 18449-02-2009 . The data obtained as a result of this task will
compliment the data determined through the ambient air monitoring network under Task 2 , and
collectively, these tasks will serve to answer the two questions above .
4.1 Model Selection and Scenarios
ERG has selected the AMS/EPA Regulatory Model (AERMOD) for use in determining
impacts from sources of interest in this study. We believe AERMOD is the most appropriate
model to implement based on the following reasons:
1. AERMOD is the U.S . EPA preferred air dispersion model for near-field (Appendix W
to 40 CFR Part 51, Guideline on Air Quality Models,
http ://www .epa.gov/ttn/scram/guidance/guide/appw 05.pdf, Page 68253);
2 . AERMOD is widely accepted and used in the scientific ·and regulatory community ;
3 . The study domain falls within the distance lim_its of AERMOD (50 km or -30 miles);
4 . AERMOD supports multiple sources types (vents, stacks , area sources for piping);
5. AERMOD needs only a single meteorological station, along with upper air data to
execute, unlike grid models ; and
6 . Special meteorological circumstances are not at issue in this case (complex wind
flows , stagnation, complex terrain); therefore, alternate models , such as CALPUFF,
are unnecessary.
ERG proposes local modeling of a limited number of proposed sites spread throughout
the city. Although several areas of the city are affected by the industry, it may be of interest to
the City to intensely study a handful of sites , representing operations across the variou s phases of
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the gas drilling and production cycle. In consultation with the City, ERG will select sites for
more detailed modeling study. For example, we might consider a simple wellpad, a more
complex wellpad with lift engines and/or a dehydrator, a gas gathering station or compressor
station , and a site affected by both a wellpad and a compressor station. Each analysis will include
analysis of impacts at facility property lines , at setback distances proscribed by the city, and at
local sens itive receptors (such as nearby parks, schools and homes). This analysis will include
our estimates of actual emissions as determined through source testing, downwash effects (if
applicable), locally collected meteorological data, and detailed land use analysis.
4.2 Model Inputs
In the case of individual site modeling, ERG staff will review facility plot plans and
aerial photography to identify property boundaries and fencelines, and uniquely identify all
emissions sources and downwash structures of interest. For all modeling performed, sources will
be correctly classified as either point , volume, or in some cases , area. Sources will also be
located in an appropriate fashion, in an effort to reflect where on the property emissions actually
occur. Source classification and placement will conform to TCEQ guidance; if there is any
uncertainty as to how a particular source should be modeled, adequate justification will be
clearly presented.
Source Parameters
The modeling submittal and electronic files will include a listing of all necessary source
parameters input to the model. These include emission rates , UTM coordinates, base elevation,
source height , stack exit velocity and temperature, and source dimensions , as applicable to each
source type. This data will be obtained at the time of the point source testing, through
development of emission factors under Task 6, or through operator interviews. In addition,
locations , dimensions , and heights of structures on the property that could contribute to building
downwash will be clearly presented. Effects of building downwash will be determined by use of
the PRIME processor.
If sources with similar parameters are combined into one source to reduce model
calculation time, justification will be provided. Effective plume heights for volume sources, if
provided, will be calculated appropriately, and volume sources dimensions will be divided by a
factor of 2.15 per EPA guidance. "Pseudo-point" sources (rain capped or horizontal stacks, for
example) will be modeled with an exit velocity of 0.1 mis. Area sources, if modeled, will
maintain an aspect ratio of no greater than l O-to-1, and no such sources will extend off property.
Emission Rates
Actual emission rates will be derived from on-site testing, or based on information
provided by site owners, as appropriate. Pollutants of interest include VOCs and HAPs,
including benzene and formaldehyde; other pollutants may be modeled as well, if future
consultation with the city dictates .
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Meteorological Data
Meteorological data is collected at several airports and samp ling stations in and around
the city, and is publically available through the NOAA and TCEQ. We anticipate that annual
meteorological data collected at the weather station closest to the modeled facility will be used as
a ba s is for our analysis, s ubject to availability and proper quality co ntrol. If not, ju stificatio n for
use of an alternate station will be presented. A de script ion of the methodology and software used
to process the data will also be presented. Some meteorological data used for this analysis may
initially include pre-processed and quality checked s urface and upper air data for the Fort Worth
area provided by TCEQ, which provides a number of dat a sets to choose from.
In all cases, the anemometer height, station identifier, and ca lendar year of the data will
be provided and input to the model. The AERMET meteorological pre-processor will be used to
prep are the data for input to AERMOD , as neces sa ry .
Recepto rs
The receptor grids developed for individual sites will consist of both appropriate
fenceline receptor s pac ing (likely 25-50 meters), as determined by the area of the facility, and
downwind receptor spacing. Maximally impacted receptors should be located in s pacing of no
greater than I 00 meters. ERG expects that most receptor grid spacing will increase as receptors
are located further from the facility, out to di stances between 5 and IO km, but the receptor
s pacing must still be dense enough to identify any maxima an d develop acc urate concentration
isopleths. Receptors will include terrain heights derived from USGS DEM information and
applied usi ng the AERMAP terrain processor. Sen sitive receptors, including individual home s,
sc hool s, parks , and other area of interest may be modeled in consultation with the city.
4.3 Model Outputs
As part of the submitted modeling analysis, summaries of model outputs will be clearly
pre se nted. Annual average, maximum hourly, and other applicable short-term averaging period
concentrations for the applicable public health evaluation threshold (such as TCEQ ' s ESL and
AQMV le ve ls) values will be reported. Summary plot s of the modeled receptor grid, along with
pollutant iso pleth s, will be included as well.
4.4 Modeling Hours and Costs
Modeling of s pecific sites of interest will require approximately 75 hours per site, but
these costs will vary with the number of sources, receptors, and pollutants modeled . The cost
estimate for this task is $39,230, based on modeling 3 single s ite sce nario s and one combined site
sce nar io as di sc us se d in Section 4.1 . Details on the cost breakdown are provided in Table 8.
5.0 TASK 5-COMMUNICATION AND OUTREACH
Outreach is needed to build trust within the community and to ensure residents that this
proj ect will meet the City's objectives, address the concerns of the citize ns of Fort Worth , a nd be
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conducted in a sc ientifically defen sible fashion. Under a separate contract (Fort Worth Natural
Gas Air Quality Pl a nning Study), ERG wi ll provide the City with a memo delineating options
and recommendations for communication and outreach activities that will achieve these goals .
ERG will work closely wit h the Cit y to di sc uss the options and recommendations prese nted in
the memo before coming to an agreement as to how to proceed with this task .
Under thi s task, we will then d eve lop a draft communication and outreach plan for
conveying the goals, progres s, and results of thi s study to the citizens of Fort Worth. Once the
plan ha s been reviewed and finalized, we will implement the communication and outreach
activities accordingly.
Note: Our cost estimate for thi s task includes costs for 7 1-day trips for project staff to
provide project updates to the City, to the public , or to attend other meetings or conferences as
requested by the City . Additional fund s have been se t aside for this task to develop and
implement the communication and outreach plan. For purposes of providing an estimate for this
work plan, the costs for this ta sk are $45,254. However, until the full scope of this effort ha s
been agreed upon with the City, a final cost estimate for this task cannot be determined .
6.0 TASK 6 -FULL BUILD-OUT ESTIMATES
Over the la st five years, there has been a dramatic increase in natural gas exploration and
production activities in the Barnett Shale, and in the City of Fort Worth itself. This increase ha s
led to concerns by the citizens of Fort Worth that their quality of life is being impacted by
deteriorating air quality due to these activities. While Tasks 1 through 5 focus on the current air
quality as contributed to by the existing natural gas exploration and production so urces, the
expansion of the natural gas industry within the City is expected to continue into the future .
Under this ta sk , the ERG team will develop point source emission factors using the data
collected under Task 3, develop growth estimates to project the number of point sources
anticipated to exist within the City under "full build-out" conditions, and use these data to
develop a city-wide emissions inventory. In thi s context, "full build-out" mean s the point at
which the natural gas exploration and production infra structure has been completed within the
City (i.e. there will be no more wells drilled ).
6.1 Point Source Emission Factor Development
Using the results of the point source te sting task (Task 3), the ERG team will develop
average emission factors for the following emission units :
• Wells
• Well pads
• Lift and line compressor engines
• Equipment leaks
• Storage tanks
• Dehydrators
• Pipelines
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The final sub-categorization of the emission units included in the emission factor
development task will be determined in consultation with the City, considering the measured
variability in emission rates for each unit type (from Task 3) and the availability of proces s data
on which to base the emission factor (from this task). Depending on availability of data , emi s sion
factors may be developed on a temporal basis (pound per hour or pound per day) or an activity
basis (pound per thousand cubic feet of gas produced). Additionally, operator data will be
collected on pre-production activities (drilling , fracturing, completion) to estimate emissions
from mobile sources (PM generated by truck traffic) and from temporary engines used on-site for
drilling, auxiliary power, and fracturing operations (PM and NOx).
6.2 Growth Estimate Development
Any projection of current emissions levels to future emissions levels will need to take
into account both the total number of emission sites (wells, well pads, treatment and process ing
sites) as well as total natural gas production levels. At some point, production of natural gas
within the City will peak, and this will likely occur prior to conclusion of full build-out (the time
at which the last well is completed). An evaluation will be made to determine the point at which
maximum emissions are likely to occur.
The data needed to conduct this evaluation will be obtained under this task from available
resources such as the U.S. Department of Energy, Energy Information Administration (EIA),
from drilling and production projections from trade groups and commercial vendors, or through
other available oil and gas activity projection resources such as Baker Hughes Rig Counts.
Additionally, surveys of the owners and operators can be used to augment future activity
estimates under full build-out conditions.
6.3 Emissions Estimates under Full Build-Out Conditions
Final emission estimates from natural gas exploration and production that are expected to
occur under full build-out conditions will be developed using the emission factors developed
under Task 6.1, and the growth estimates developed under Task 6.2. All assumptions and
calculations used to prepare the full build-out inventory will be documented and reviewed with
the City prior to finalization .
6.4 Full Build-Out Evaluation Hours and Costs
The cost estimate for this task is $10,900, which assumes that baseline emjs s ions will be
linearly extrapolated to full build-out emjssions based on the maximum projected natural gas
production rate within the City at some point in the future as compared to current production . A
more refined analysis, such as attempting to provide geo-specificity to the full build-out
inventory, would require additional resources. Details on the cost breakdown are provided in
Table 8.
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7.0 TASK 7-FINAL REPORT
An all-inclusive final report presenting the findings of this study will be prepared under
Task 7 . A proposed outline for th e final report , including a brief description of the content of
each sect ion , is provided below .
Se ction 1 -Ambient Monitoring Methodology and R esu lts
Thi s sectio n will present a summary of the findings of the ambient air monitoring
network, with detailed analytical results for each monitoring sample presented in an Appendix.
The discussion will provide details on network development , network implementation, the
methodology used to collect and analyze the samples, the quality assurance/control control
(QA/QC) results, and any changes made to the ambient network monitoring design as the project
progressed.
Section 2 -Point Source Testing Methodolog y and Results
This section will present a summary of the findings of the point source testing task (Task
3), with detailed analytical results for each point source presented in an Appendix . The
discus sion will provide details on point source identification, the sampling approach, the
methodology used to collect and analyze the samples, the QA/QC results, and any changes made
to the point source testing plan as the project progressed .
Section 3 -Disp ersion Mode ling Methodolog y and Results
Thi s sect ion will present a summary of the dispersion modeling effort, including model
input parameters (stac k height , emissions rates, meteorological data), model methodology
development , and modeling results .
Section 4 -Publi c Health Evaluation
• Are the City's setbacks for wells, tanks, and compressors adequate to protect public
health?
This section of the report will evaluate public health impacts associated with natural gas
exploration and production activities to provide context for the question about the adequacy of
setbacks. The public health evaluation will integrate findings from numerous data sources. Much
of the focus will be on pollutant concentrations determined under Tasks 2 (Ambient Air
Monitoring) and 3 (Dispersion Modeling), and these will be compared to relevant state, federal,
and international health guidelines. Consideration will be given to both cancer and non-cancer
health effects and evaluation of both acute and chronic exposure durations.
More detailed evaluations will be offered for pollutants found to exceed their
corresponding health guidelines. These evaluations will summarize information on the health
effects of the pollutant of concern , primarily by reviewing the relevant toxicological and
epidemiological literature. The detailed evaluations will also consider any unique health risks
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experienced b y s u sceptible populations (e.g., children, the elderly, and persons with pre-existing
health conditions). Uncertainties in the public health evaluation will a lso be identified a nd
discu ssed, and so me di sc us sio n will be included on the potential public health implications
regarding s imultaneou s exposures to mixtures of multiple pollutants .
Additional context will be provided by comparing mea sureme nts made during this
program to those made during other st udi es that h ave examined air quality impacts of Fort
Worth's oil and gas exploration activity. The meas urements will a lso be compared to levels
typically m easured in similar urban and s uburban settings, for further p erspective.
Section 5 -Regulato ry Assessment
• Do the sites comply with applicable regulatory limits?
Upon completion of the point so urce testing task, facility-level emission estimates
developed for wells, well pads, gathering stations, treatment a nd process in g plants, a nd disposal
facilities will be evaluated against various regulatory thresholds and standard s . Reg ulatory
standards to be considered include TCEQ 's permit-by-rule and stand ard permit threshold s, Title
V Operating Permit thresholds, New Source Review (NSR) thresholds for Prevention of
Significant Deterioration (PSD) and Nonattainment NSR, and EPA's NESHAP and Maximum
Achievable Control Technology (MACT) standards.
Section 6 -Full Build-Out Estimates
This section of the report will present a s ummary of the result s of Task 6, including the
point source emission factors developed under Task 3, and an assessment of both baseline
emissions (current conditions) and emissions at full build-out.
Section 7 -Conclu sions and R ecommenda ti ons
The final sect ion of the report will present our conclusions as to the findings of the study,
as well as recommendations for future considerations.
The cost estimate for this task is $41,092, with much of this effort dedicated to the public
health evaluation in Section 4 (approximately $18,000). Detail s on the cost breakdow n are
pro vided in Table 8.
8.0 TIME LINE (SECTION 8.0 REVISED AUGUST 16, 2010)
The proposed schedule for this project is shown in Table 7 below. The dates in this table
are based on iss uance of the Notice to Proceed (NTP) on August 20, with the dates for final
products based on the City's review and approval of the associated draft deliverables within
seve n days of receipt. If s ituations arise such that the City 's review takes longer than seven days ,
s ubsequent project milestone date s will have to be re-evaluated to ensure they can sti ll be met.
As necessary, ERG will propose revi sed milestone dates.
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group, Inc .
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Page 53 of 73
Fort Worth Natural Gas Air Quality Study Revised Final Work Plan Section 8.0 TIME LINE August 16, 2010
Table 7. Projected Schedule for Fort Worth Natural Gas Air Quality Study
Milestones
Task 1 -Project Management
1.1: Monthly Progress Reports and Invoices
Task 2 -Ambient Air Monitoring
2.1: Final Ambient Air Monitoring Plan
2 .2 : Site Selection and Network Setup
2.3 : Commence Ambient Air Sample Collection
2.4 : Conclude Ambient Air Sample Collection
2.5: Ambient Air Monitoring Report
Task 3 -Point Source Testing
3 .1: Final Point Source Test Plan
3 .2 : Commence Point Source Testing
3 .3: Conclude Point Source Testing
3.4: Point Source Testing Report
Task 4 -Air Dispersion Modeling
4.1: Complete Facility Plot Plan Review
4 .2 : Complete Valuation of Source Locations and Release Parameters
4.3: Complete Review of Receptor Placement and Classification
4.4: Meteorological Data Analysis (if necessary)
4 .5: Model Execution and Review of Results
4 .6: Air Dispersion Modeling Report
Task S -Communication and Outreach
5.1: Draft Communication and Outreach Plan b
5.1: Final Communication and Outreach Plan
Task 6 -Full Build-Out Estimates
6 .1: Draft Full Build-Out Estimates
6 .1: Final Fu ll Build-Out Estimates
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc.
33
Planned Date
15th of Each Month
To Be Determined a
August 30 -
September 3, 2010
September 7, 2010
November 16, 2010
December 10 , 2010
August 20, 2010
August 30, 2010
November 30 , 2010
January 14 , 2011
December 10 , 2010
December I 0, 2010
December I 0, 2010
January 14, 2011
February 11 , 2011
March 11 , 201 l
September 7, 2010
September 21 , 2010
December 23, 2010
January 14 , 2011
Page 54 of 73
Fort Worth Natural Gas Air Quality Study Revised Final Work Plan Section 8.0 TIME LINE August 16, 2010
Table 7. Projected Schedule for Fort Worth Natural Gas Air Quality Study (Cont.)
Milestones Planned Date
Task 7 -Final Report
7.1: Draft Final Report March I I , 2011
7 .1: Final Report March 25, 2011
a The Final Ambient Air Monitoring Plan under Task 2 .1 will include final site locations . As such , thi s
deliverable will be submitted within 7 days of final site selection.
b The deliverable date for the draft Communication and Outreach Plan is contingent upon finalization of
the Communication and Outreach Memo (being done under Contract No. 4063 1 -Natural Gas Air
Quality Study Planning) by August 24, 20 I 0 .
9.0 BUDGET
Table 8 provides a breakdown of labor costs and labor hours for the project by task .
Table 9 shows the estimated hours for the project by individual staff, and indicates non-ERG
staff.
Table 8. Estimated Costs to Perform Fort Worth Natural Gas Air Quality Study
Task
1. Project Management
2. Ambient Air Monitoring
-Labor
-ODCs (Travel, Equipment, Analytical Costs)
3. Point Source Testing
-Labor
-ODCs (Travel, Equipment, Analytical Costs)
4. Air Dispersion Modeling
5. Communication and Outreach
-Labor
-ODCs (Travel, Outreach Materials)
6. Full Build-Out Estimates .
7. Final Report _
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc .
TOTAL
34
Total Costs
Hours Dollars
143 $22,020
982 $104,844
NIA $123,227
1,398 $160,012
NIA $86,465
310 $39,230
256 $36,560
NIA $8,694
100 $10 ,900
308 $41,092
3,497 $633,044
Page 55 of 73
Fort Worth Natural Gas Air Quality Study Final Work Plan
Table 9. List of Staff Members for Fort Worth Natural Gas Air Quality Study
Staff Member
Art Bedro sian (Sage)
Dave Dayton
Erik Epple (Hicks)
Karla Faught
Katie Ferguson (Sage)
Scott Fincher
Kerry Fo un tain
Jamie Hau se r
Chris Lehman (Sage)
Matt O'Neill (Hicks)
Regi Oommen
Heather Perez
Mike Pring
David R anum (Sage)
Sarah Roy ste r
Scott S holar
Arney Srackangast
Sage Tech Support (Sage)
Jody Tisano
Stephen Treimel
Peter Van Zandt (Hicks)
Tom Van Zandt (Hicks)
John Wilhelmi
Rodney Williams
Professional Services Cont ra ct
Air Quality Study -Final Work Pla n
Eastern Research Group , Inc.
Labor Classification Total Hours
Con sulting Engineer/Scientist 45
Principal Engineer/S cientist 128
Staff/Technician Support 320
Associate Engineer/Scientist 80
Staff Engineer/Scientist 140
Staff Engineer/Scientist 150
Staff/Technician Support 16
Associate Engineer/Scientist 20
Mid -level Engineer/Scientist 320
Staff/Technician Support 360
Mid-level Engineer/Scientist 181
Associate Engineer/Scientist 100
Senior Staff Engineer/Scientist 257
Principa l Engineer/S cientist 280
Intern Engineer/Scientist 65
Associate Engineer/Scientist 140
Mid-level Engineer/Sc ientist 150
Staff/Technician Support 4
Staff/Technician Support 48
Associate Engineer/Scientist 165
Staff/Technician Support 320
Consulting Engineer/Scientist 8
Principal Engineer/Scientist 176
Associate Engineer/Scientist ! 24
TOTAL 3,497
35
Page 56 of 73
Fort Worth Natural Gas Air Quality Study Final Work Plan
10.0 OPTIONAL STUDIES
10.1 Ambient Air Monitoring (Optional Long-term Study)
This task was not originally listed in the Request for Qualifications, but the City
expressed interest in potentially extending the short-term monitoring study to at least one -year to
obtain true long-term (annual) monitoring data. After evaluating initial short-term results, it may
become evident that some, if not all the short-term sites should be used for long-term monitoring.
We envision that once long-term monitoring begins , the samp lin g schedule would convert from
once every three days to once every six days. Thus, in one year, approximate ly 70 samples may
be collected at a site, which is more than sufficient in developing an annual average suitable for
long-t erm exposure comparisons.
Similar to the short-term study, we propose sampling for VOCs, SNMOC, and methane.
Carbonyls would not be collected under this scheme unless the initial screening showed result s
indicating the need for a lon g-term evaluation. It is strongly recommended that long-term
monitoring begin at the end of the short-term monitoring without delay, such that a years worth
of samp le s can be collected by mid-August 2011. Table IO presents the long-term number of
samp le s needed to accomplish this task. Note that ERG's cost estimate does not include the costs
for performing this task.
Table 10. Proposed Approach and Schedule of Collection Events for the Long-Term
Ambient Monitoring Network Element of the FT. Worth Survey Study
Parameter Concurrent VOC/SNM OC/Methane
VOC/SNMOC/Methane Duplicate samples
Number of Samples 50 samp le s * 5 sites = 250 13 samp les * 2 sites = 26
(1-in-6 days)
Overall Total Samples = 276
10.2 Ambient Air Monitoring (Optional Well Site Life-cycle Study)
This task was not originally listed in the Request for Qualifications , but the City
expressed interest in a specialized short-term study evaluating activities during the "lifecycle" of
a production well. The lifecycle includes: pre-bit activities , drilling and fracturing activities ; well
completion activities; and production activities. The City estimates that these activities typically
occur during a 6-month period. To accomplish this task, we envision the fo1lowing schedule:
.1) pre-bit activities: one site, sampling once every 6 days
2) drilling and fracturing activities: five sites, once every three days
3) well completion activities: five sites, once every three days
4) production activities: one site, sampling every 6 days
Monitoring sites would be situated around the fenceline surrounding the wellpad. Additionally,
we recommend installing an anemometer at the fenceline to capture the behavior of the wind
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc.
36
Page 57 of 73
Fort Worth Natural Gas Air Quality Study Final Work Plan
during this study . Finally, we envision sampling for the same suite of pollutants as the long-term
study (VOCs , SNMOC , and methane). Note that ERG's cost estimate does not include the costs
for performing this task.
10.3 Ambient Air Quality Impact of Full Build-Out Conditions (Optional)
The impact on ambient air quality due to full build-out of natural gas exploration and
production would be determined under this task using air quality modeling. Note that ERG 's cost
estimate does not include the costs for performing this task; however, a brief discussion of how
this task could be carried out is provided, along with identification of some of the issues involved
in this type of analysis.
While it is expected that the concentration of pollutants such as benzene in the ambient
air due to natural gas exploration and production would increase under full build-out conditions
on a city-wide basis, impacts to an individual street or residence are more likely to be related to
their proximity to an individual source (e.g., well pad) rather than to the total number of sources
within the City limits.
Given the relative magnitude of emissions from all source types (i.e., point sources, area
sources , mobile sources), changes in air quality in the City due to other sources (especially motor
vehicles) would most likely have a much greater impact on predicted ambient air concentrations
of a specific HAP (e.g., benzene) than would changes in air quality due specifically to natural
gas exploration and development activities. Additionally, any prediction of future air quality
would need to take into account changes in state and federal air quality rules. Examples of these
types of considerations include:
• Changes in traffic patterns and population growth
• Proposed revisions to TCEQ rules such as the Permit by Rule for Oil and Gas
Production Sites (106.352)
• Additions or changes to the U.S. EPA's National Emissions Standards for
Hazardous Air Pollutants (NESHAP) for oil and gas sources
Although these considerations would affect the City's air quality in the future , it is
possible to develop an estimate of the impact that full build-out conditions would have on the
City's air quality. ERG proposes an overall, city-wide modeling analysis conducted in
"regulatory" mode, similar to what industrial facilities do for permits. In this case, we would
model maximum emissions (based on the results of the point source testing, supplemented with
permitted emission rates if necessary) for selected pollutants as determined under Task 6.3 , using
TCEQ model-ready meteorological data. Note that this is not a "real-world" analysis, but rather
would be intended to provide an estimate of what the maximum impacts could potentially be.
The downside of this approach is the modeling analysis will most likely overestimate impacts,
due to the conservative modeling assumptions , and due to the lack of geo-specificity of the
locations of the sites at full build-out. However, if conservative results obtained using worst-case
assumptions are below concentrations of concern, a large degree of confidence is achieved that
the public would not be subject to adverse air quality due to full build-out of natural gas
exploration and production in the City.
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc.
37
Page 58 of 73
Fort Worth Natural Gas Air Quality Study Final Work Plan
Appendix A -Point Source Analytical Methods and Detection Limits
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc.
Page 59 of 73
Fort Worth Natural Gas Air Quality Study
Analyt ~
TOJ5_Source in Air (T0-15)
Pre:sl!rv:1tfon: lore sellled at STP
Cc, 111ll in~r: Passivated Canister
Propylc,ic
Ch lo rod iD uooro,ncthanc
Dich lorodifluoromc(l,nnc
Ch loromclh=
1.2-Dichloro· l, 1,2,2 -tmall 11ororth""'
Vinyl chlo ride
1,3-Butadrcne
Butane
Bro,nomethanc
Chlo1oethan<
V inyl b,onridc ---bop~n ,a uo
Trichforofluorome lluuic
Acct.one .. , I. -1 .. .I m•-
11-P,:nt.,nc
Dietlry J dh~r
l ,l-Dichloroetltenc
l\kthylcnc chloride
t-Buuwol
Carbon dis ulfide
Allyl chloride
1.1.2-T,!~lorolril'luoraothane
I rans-l ,2-Dich lorn cl.hen~
1, 1-Dichlorocthaoe
Methyl ter1 -Dui:yl Ethe,
Vinyl •cxme
2-Butanonc (MI'.K)
ds-l ,2.-0 ichlorocilK:nc
1-lcxan.e
Chloroform • •
1,2-D1cl1 lo rocthano
I. f.1-Trichloroe.Chonc
Be.ill.CUC
Carbon tctrac.h loridc
~
Cyc lohc~n.no
Dibromomelll.me
1.2-Dich loroprupm,e
O romo<ll ch 1o rnmcthll11C
Professiona l Services Cont ract
Air Qual ity Study -Fi nal Work Plan
Eastern Research Group , Inc .
1'1DL
0.00326
0.001 12
0.00159
0.00119
0.00.128
0.002}4
0.00300
O.O<l 160
0.0211
0.00263
0.00397
0.00281
0.00507
0.0 04 82
0 00212
0.0008·10
0.00434
O.O<n34
0.0051(,
0.00189
0.0043'1
0.00208
0.00205
0.00399
0.00 110
0.00289
0.00106
000161
0.00122
0.00272
0.0026'1
0.00322
0.00157
0.00 14 0
O.QO I S)
0.00272
0.0025 9
0.000830
0 .00 155
0.0025J
0 .00135
0.00393
0.00 ,69
0.00 192
0.00144
0 .00137
Final Work Plan
TcstAmcric,1 Austin 1m2010
An alytical Method Information
Reporting S11 rr ogilte Duplic:a tc M•triA Spike Bl •11k Spil,c / LCS
L imit %R RP O •11,11. RPD ?~R RI'(>
Amount Rcquin:,J:6000 mL Hold 'l'iJnc:30 dB)lli
U.0200 ppmv 25 62-122 25
0.0200 ppmv 25 71 · 131 lS
0.0200 ppmv 25 70 • 130 25
0 .02.00 ppmv 25 58 • 11 8 25
0.0200 ppmv 25 65 • 125 25
0.0200 ppmv is 64-124 25
0 .0 200 pprnv 25 6'1 · 12 4 25
o.owo J)JJ111V 25 66-126 25
0.0500 ppm,• lS 79 -1}9 ll
0.0200 ppmv 25 66 · 126 25
0.0'J.00 Pl'"" 25 67 -127 25
0.0'lOO pp mv 2S 68 • 128 '25
0.0200 ppmv 25 73 -I 3 25
0. 0200 ppnw 25 76 -136 25
0.0200 [\pmv 25 ?J -133 25
0.0200 ppm, 25 70 -1)0 25
0.0200 ppmv 25 62-122 25
0.0200 ppm,· 25 50 · 150 25
0.0200 ppmv 25 68 · 128 25
0 .0200 ppmv 25 65 -125 25
0.olOO ppmv 25 67 • 127 l~
0.02-0 U ppmv 25 64 -124 25
0.02:00 PJ>III V 25 55 • 115 25
0 .07:00 wnw 25 73 · llJ 25
0.0200ppm, 25 70 • I io 25
0 .020() j>pmv 25 71 -Il l 2S
0.0200 ppnw 25 M -124 25
0.0200 ppm,• 25 71 • 1 1 2S
0.0200ppmv 25 66 • 12(, 25
0·.0200 ppmv 25 80 · 140 25
0.0200 Pi>IDV 25 95 -155 25
0.0200 ppmv 25 70-130 25
0 .0200 µpmv 2.5 6{;-126 25
0 .0200ppmv 25 64 -124 25
0 .0200 ppm,• 25 73 , 133 25
O.OWO p pnw 2.5 70 · 130 25
0.0200 ppm,, 2.S 65-m 25
0.0200 ppmv 2 5 73 • 133 25
0.0200 ppmv 25 75 · 135 25
0.0200 pprnv 2S 6 1 -12 1 25
0.0200 ppmv 25 80 -140 25
0 .(l200 ppmv 25 50 • ISO 25
0 .0200 ppmv 25 66 -126 25
0.0200 l'PITIV 25 70 • l:lO 25
0.0200 ppnw 25 65 • 12 5 25
0.0200 p pmv 25 71 -13 1 25
Page \ nfJ
A-1
Page 60 of 73
Fort Worth Natural Gas Air Quality Study
An•lyto
T,icli lo roc<hcnc
2,2.4-Trimelhylpeninne
Methyl mcth.ncrylate
H~plane
cis-l ,J-Dicl!lorc,propen e
4-Methyl-2•pcntano11c {MI BK)
lr ens· 1,3·Di cl1loro propene
I , I ).-lrkhforo~h,me
To luene
2-Hc•annne
Chlorodibromomclhnnc
. l .2-Di b,on,oeth,,~o (EDB)
n~Oc:utnc
Tctrachloroeth<:ne
Cliloro benze ,,c
E rh ylhcnzc,ic
,m-Xy lcnc & p-Xylcne
Bmmofom,
S1y,cr,c
1,1,2,2-Tetrachlornethane
a-Xylen e
1,2,l-Tric hloropr opwl'C
n-Nonane
lsop<opyll>c n7;,n<
2-Chlnmtolucnc
n-Pm pyl ben2e11e
4 -f(hyl lt lucnc
l, 1,5-T rimclhyl be nz:enc
nlpha-Mcthytslyr~ne
1.2,4-Trimclhylben~cne
tct1-Ru tylbenzcre
Ben zy l chl o ri de
1.3-Dkhlorobcni,:nc
o-Oe:cnn c
1,4-Dich lorobcnz.:nt
:scc -Butylbenzene
"··wopr<;ipyltolucne
1,2-Dich lo robenune
n-Butylbe,,zene
11-Undcca,w,
1,2.4 -Tricbl orobenzt"J1c
Nnphthalene
nMDodtcllne
l ,2,3~Tri chlorob enume
1-1,.,achlorobutoolcne
~u.rr: 4-Bromofluorobanene
sun-: 1.2-(}ichloroc.thone-,H
Professional Services Contract
Air Quality Study . Final Work Plan
Eastern Research Group, Inc .
MDL
0 OOSS2
0 .00209
0.00 1•13
0 .00237
0 .002<!6
0 .00211
0.00168
0 .001.10
0 .001%
0.0032 1
0.00 197
0 .00 100
0.00 1 J9
0 .00 187
0.0051 5
0 .00119
0 .00?:09
0 .0016 7
O.OOO<J.40
0 .0023 7
0Al0104
0.001 63
0 .00239
0 .00 l !H
0.00 183
0.00 175
O.OOW1
0.002!0
0 .00246
0 .00252
(l.00213
0.002.10
000 190
0.001 7 7
0 .002)1
0 .00 192
0.00265
0.00 1~9
0.00'25.'.5
0.00243
0.00194
0.002 15
0.005 14
0.00629
0.00 264
0.0054 9
0.00 196
Final Work Plan
TestAmerica Austin ?n/20 10
TestAmerica Austin ?n/20 10
Analytical .Me tho d Info rrn:1tion
RC!p,orti.n~ Surrog,atc Ouplicute Motrix Spike Blunk pike /LC
Limit %R Rl'O %R RPI> %R RPO
0.02 00 ppmv 25 6-1 -124 25
0.0200 ppmv 25 65 -125 25
0.02 00 i,pmv 25 66 • 126 1S
0.0200 wmv 25 71-1.l7 25
0.0200 p prnv 25 71 • IJ I 2S
0.0200 p prnv 25 n -1H 2S
0 0200 ppnw 25 7-1 -IJ4 25
0.0200 ppmv 25 83 -143 25
0.0200 pp m,• 1S TI -IJ) 25
o.<n oo pprnv 25 69-129 25
0.0200 Pl>m V 25 S2 -1 12 25
0.0200ppmv 25 RJ -i J J 1
0.0200 ppil lV 25 7 1 -13 1 2 5
0.0200 PPDIY 25 68 -12H 25
0. 0200 p pntv 25 70 · 1)() 2S
0.0200 p pnw 2.l 69 -129 25
0.0200 1>1lm" 25 7 1 -I J l 25
0.0400 ppmv 2:1 76-I J6 25
0.0200 ppmv 25 87-14 7 25
0 .o?.00 p pmv 25 82 • 14 2 25
0.0200 ppmv 25 HI· 141 25
0.02 00 Pl'"" 25 7 8 -13 8 25
0.0400ppmv 25 77 -137 25
0.02 00 ppmv 25 77 · JJ7 ZS
0. 0200 ppm,· 25 76 -J1(, 25
0 0200 ppnw 25 74 -13.IJ 25
Cl .0200ppn 25 77-137 2.l
0.0200 pp nw 25 8 1 • 14 1 25
0.01.00 ppnw 25 86-1•16 25
0 .0200 ppnw 25 8 6 -146 2.l
0 .0200 ppmv 25 90 -LSO 25
om.oo ppm v 25 &7 · 141 25
0.020Hppmv 25 79 -139 25
0.0200pi,mv 25 98 -l 58 25
0.0200 Pl>"'' 25 9,1 -15-4 25
0.0200 ppmv 25 79 -JJ9 2 5
0 .0200ppmv 25 88 • 148 25
0 0200ppl'IW 25 78 • 1 lR 25
00200 p pnw 25 85 -145 25
0 .0200 pprnv 25 87 -J4 i 25
0 .0200 pp1nv 25 8 7 -147 25
0 .0200 ppmv 25 K2 -142 25
0.0200 ppmv 15 98 · 158 25
0 .0200 pp,nv 25 n -i n 25
0 .01.00 ppmv 25 R2 · 1-12 25
0.0200 ppmv 25 86 · 146 2.l
0 .0200 ppmv 25 9 1 -151 25
25 10-1.10 25
72 -IJ2 25
79 -139 25
Pll!,'t 2 of 3
A-2
Page 61 of 73
Fort Worth Natural Gas Air Quality Study
An•lytc
sua: ToJuc nc,-dS
I ,•1--0 illumobcozwo
Bro mo cJ,l.oromc:thn.11e
Chlorobtrn cn c-<l 5
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc.
MDL
T cstAme ri c a A us-tin
A n alyti ~I Me th od Iofornmti.0 11
R •porl.i ng SurrOjlato Duplic,le
Li mit %R IU'l>
70 • 130
A-3
Final Work Plan
7/7/'lOlO
Matrix S pi ke lllonk pll<• I l,CS
%R ru•o %R RPO
Pagel of3
Page 62 of 73
Fort Worth Natural Gas Air Quality Study
Ana lyle
D 1946_Po5itive in Air (1)1946)
'Pr.,erntion:Store sealed at STP
Cont•incr:1':iss ivated Can islc r
O;icygcn
Nitrogtn
Methane
Carbon monoxide
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc.
MDL
0.01 99
0.020 1
0.0877
0.0545
TcstAmcrica A ustin
Analy1ica l M e thod Informalion
Reporti ng Sv rrogalo Dupllca re
!Amit 'YoR RPD
Amount Rcquircd :6000 ml.
I.OO'Y.{,'/v) 25
S.OO~vtv) 25
W Oo/o:{\'/v) 25
J .00 'X{vl v) 25
A-4
Final Work Plan
717/2 010
M atrix S pilte Ulunk Spil<A: I LC
'I.I! IU'D %R RPD
Ho ld Tlme:30 days
7$ · 135
70 • 130
73 • 13 3
71 -lJ I
2S
25
25
25
['age I of I
Page 63 of 73
August 6 , 2010
Appendix B -Addendum: Clarification of Point Source Testing
(August 6, 2010)
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc.
Page 64 of 73
August 6, 20 I 0
The purpose of this addendum is to acknowledge and reaffirm the requirements of the Scope of
Services in the Request For Qualifications and Addendum #2, specifically related to point source
testing during well completion activities. It was always our intention to conduct point sources
testing for these types of activities during the preparation of our Qualifications Package , the
Qualifications Interview with the Air Quality Committee on June 30 , 2010 , the kickoff meeting
with the City after selection , throughout the negotiations and discussions with the City , and
during the development of the Work Plans for Contract# I and Contract #2. We felt like we
have acknowledged our understanding of this important natural gas activity source , as we made
revisions in our Work Plan for Contract #2 to address this issue. The ERG Team is committed to
performing point source testing for one or more well completions, including flowback during this
study.
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Rese arch Group , Inc.
B-1
Page 65 of 73
ATTACHMENT B.
FEE SCHEDULE
Prices for professional services rendered under this contract will be as specified in the
schedule provided in the following attachment entitled "Eastern Research Group , Inc .
and City of Fort Worth , Contract Fee Schedule -Air Quality Study , Natural Gas Air
Quality Study , Second Contract" and dated August 1, 2010 , consistent with the terms of
this contract and subject to the not-to-exceed amount.
Professional Services Contract
A ir Quality Study -Final Work Plan
Eastern Research Group , Inc . Page 66 of 73
-0
Q)
(0
(I)
a, .....
s. .....
(,)
Eastern Research Group, Inc and City of Fort Worth
Contract Fee Schedule • Air Quality Study
Natural Gas Air Quality Study, Second Contract
August 1, 2010
This is a time and materials (T&M) proposa l. Prime and subcontract labor will be invoiced to Ft. Worth at burdened hourly rates , below.
LABOR Category
Consulting En gineer/Scientist
Principal En gineer/Scientist
Senior Staff Engineer/Scientist
Mid-level Engineer/Scientist
Staff Engineer/S cie ntist
Associa te Engineer/Scientist
Staff/Technician Support
Intern Engineer/Scien tist
8/1/10-9/30/11
Ratrt
$
$
$
$
$
$
$
$
218
179
141
132
115
103
84
60
Representative Personnel or Equivalent•
Art Bedrosian (Sage)
Dave Dayton (ERG), Ray Merrill (ERG),
Clint Burklin (ERG), John Wilhelmi (ERG).
Paula Fields (ERG). David Ranum (Sage),
Andrew Poth (Hicks), Melita Elmore (H icks )
Tom Van Zandt (Hicks)
Mike Pr ing (ERG)
Regi Oommen (ERG), Arney Srackangast (ERG)
Steve Mendenhall (ERG),
Scott Finche r (ERG), Jason Renzaglia (ERG)
Chris Lehman (Sage), Katie Ferguson (Sage)
Rodney Williams (ERG), Scott Sholar (ERG),
Heather Perez (ERG), Stephen Tre imel (ERG),
Stacie Enoch (ERG). Jamie Hauser (ERG),
Tracy Parha m (ERG), Karla Faught (ERG),
Jerad McCleland (Hicks)
Anita White (ERG), Jody T isa no (ERG), Matt
O'Neill (Hicks), Erik Epple (Hicks),
Peter Van Zandt (Hicks)
Sarah Royste r (ERG)
*ERG team may subs titute equivalent personnel after consultation wi th the City without modification
to the resulting contract.
Non-labor costs will be prov ided at cost to prime or subcontr,ictor.
ERG PROPRIETARY INFORMA T/ON
i'.l
Q)
"' (t)
a,
co
a
-.J w
Consulting Engineer/Scientist
Principal Engineer/Scientist
Senior Staff Engineer/Scientist
M id-leve l Engin eer/Scientist
Staff En gi neer/Scienti st
Associate Eng ineer/Scientis t
Staff/Technician Support
Intern Engine er/Scienti st
Total
ERG RTP Office Travel ·
ERG Lab Travel·
ERG Lab ODCs (field)"
Te sta merica for ERG
ERG Copie s/Phone
ERG Fixed Price Analysis-
Sage Tr avel "
Sage ODCs·
Sage Analytical Subcontract·
Hicks Tra ve l-
Hicks ODCs•
Total Price
*S ee following sche dule for ite mized costs .
Rate
$ 218
$ 179
$ 14 1
$ 132
$ 115
$ 103
$ 84
$ 60
M;ai\.1 1jeirietr( !
r.:a~~(::: i Hours
15 $ 3,270
0 $
128 $ 18 ,048
0 $
0 $
0 $
0 $
0 $
143 $ 21,318
$ 702
$ 22,020
HOURS AND COSTS BY TASK
:trt 1:~0t1~nr~ """'''~'.'t}··tt ! ~'r°1tmt\~~d~r.r9 <FtrM.~t~~ ,' < '':!t1l?tr > ! · 1vu::~t'"1 · ..•. r:0r1~s >>
Hou rs Hours S Hours $ Hours H ou rs Hours H ours
10 $ 2 ,180 10 $ 2 ,1 80 10 $ 2,180 0 $ 0 $ 0 $ 45 $ 9,810
92 $ 16,468 284 $ 50,836 0 $ 116 $ 20,764 0 $ 100 $ 1?.900 592 $ 105 ,968
40 $ 5,640 0 $ 0 $ 24 $ 3,384 25 $ 3 ,525 40 $ 5,640 257 $ 36 ,237
100 $ 13 ,200 0 $ 150 $ 19,800 16 $ 2 .112 25 $ 3 ,300 40 $ 5,280 331 $ 43 ,692
0 $ 460 $ 52,900 150 $ 17 ,250 0 $ 0 $ 0 $ 610 $ 70,150
324 $ 33,372 0 $ 0 $ 100 $ 10,300 25 $ 2 .575 80 $ 8 ,240 529 $ 54,487
376 $ 31.584 64 4 $ 54 ,096 0 $ 0 $ 0 $ 48 $ 4,032 1068 $ 89,712
40 $ 2,400 0 $ 0 $ 0 $ 25 $ 1 .500 0 $ 65 $ 3,900
982 $ 104 .844 1398 S 160,012 310 $ 39,230 256 $ 36,560 100 $ 10,900 308 $ 41,092 ~$ 413,956
$ 8,694 $ 8,694
$ 9,143 $ $ 9,143
$ 16,920 $ 16.920
$ 16,500 $ 16,500
$ 702
$ 77,73 1 $ 77.73 1
$ 18.475 $ 18,475
$ 41 ,784 $ 41 ,7 84
$ 20,240 $ 20,240
$ 2,633 $ 5,267 $ 7,900
$ 300 $ 700 $ 1,000
$ 228,071 $ 246,477 $ 39,230 $ 45,254 $ 10,900 $ 41,092 I $ 633,044
ERG PROPRIETARY INFORMATION
ITEMIZED SCHEDULE OF TRAVEL AND ODCs FOR ERG, SAGE AND HICKS
E RG -RT P Offi c e T ravel
Assume 7 trips, RTP , NC to Fort Worth , Texas
Airfare $ 750 per trip 7 trips $ 5,250
Lodging $ 240 per trip 7 trips $ 1,680 Assume 2 nights at $120/n ig ht
Meals $ 92 per t rip 7 trips $ 644 Assume 2 days @ $46/day
Vehicle (Car) Rental $ 120 per trip 7 trips $ 840 Assume 2 days/trip @ $60/day
Fuel $ 40 per trip 7 t rips $ 280
$ 8 ,69 4
§chedule b',' Month
August 1 Regi Oommen
September 1 John Wilhelmi, Mike Pring /Regi Oommen already there
October 0
November 1 Mike Pring or Regi Oommen
December 0
January 1 Mike Pring, Regi Oommen, or John Wilhelmi
February 0
March 3 John Wilhelmi, Mike Pring , Regi Oommen
ERG -Lab T ravel
Deplo','m§nt:
A irfare $ 750 per trip 2 trips $ 1 ,500 2 staff members , refundable tickets
Lodging $ 120 per night 12 n ig hts $ 1,440 6 nights , 2 staff
Meal s $ 46 perday 14 days $ 644 7 days, 2 staff
Vehicle (\/an) Renta l $ 125 per day 7 days $ 875
Fue l $ 350 per trip 1 trip $ 350
Fie ld Supt:1Q!!
Airfare $ 750 per trip 1 trip $ 750 1 staff member, refundable ticket
Lodging $ 120 per night 2 nights $ 24 0 2 nights, 1 staff
Me als $ 46 pe r da y 3 days $ 138 3 days, 1 staff
Vehicle (\/an) Renta l $ 125 per day 3 days $ 375
Fu el $ 100 per trip trip $ 100
Field Re covery :
Airfare $ 750 per trip 2 trips $ 1 ,500 2 staff members, re fundable tickets
Lod ging $ 120 per night 4 ni g hts $ 480 2 nights , 2 sta ff
Meals $ 4 6 per day 6 days $ 276 3 days, 2 staff
"U
<ll Ve hicle (\/an) Rental $ 125 pe r day 3 da ys $ 375
(C
(l) Fu el $ 100 pe r trip 1 trip $ 100
a,
c.o s. $ 9 ,143 ..._,
w
m )> "O ERG -Lab ODCs (F ie ld) w ~-a
~ o ro ~ C Cf.I
:::, 0) (/) In-house PreQ and Field DeQloyment: = i5 " ~![ 1/8" S S Tubing (1) $ 300
~ K g, 1/4" S S Tubing (1) $ 325
g. ~ S. Refrigerator $ 400
Gl ..,, r, Misc. fittings (1) $ 630 a:,·~ Misc. hardware (1) $ 720 C ~ (")
}' :'E g Packing tape for field use (1) $ 80
3" 0 ~ Field tools (for operators) 3 @ $60 each) $ 180 r, ~ 0)
• "" C) Shipping equ ipment/materials to site (1) $ 1,000 "Cl -iii Copies (70 @ .07/copy) $ 5 :::,
In-house SUQQOrt
Shipping fo r canisters (130@ $75/round trip, 40@ $35 one way to Test America) $ 11 ,150
Veriflow rental (5 @ $210/12 weeks) $ 1,0 50
Packing tape fo r in-house use (1) $ 80
Field and In-house Recove[Y
Shipping equipment/materials from site (1) $ 1,000
$ 16 ,920
ERG -Lab Fixed Pr ice Ana lysis
QrL Un it Pr.
Concu rrent A .T./S NMOC 1 10 $ 578 .50 $ 63 ,635
Carbonyls 50 $ 155.00 $ 7 ,750
T0-15 Certification 7 $ 805 .0 0 $ 5,635
T0-1 1A Certification 2 $ 355 .50 $ 711
$ 77 ,73 1
Sag e · Travel
Airfare (Lubbock-Dallas) $ 400 per trip 3 trips $ 1,200
Airfare (Houston-Dallas) $ 300 per trip 3 trips $ 900
Lodging $ 1,200 per month 2 months $ 2,400 2 BR apartment
Lodging (hotel) $ 120 perday 3 days $ 360
Meals $ 39 perday 75 days $ 2,925
Car Rental $ 55 per day 6 days $ 330
Van Rental (2) $ 1,770 per month 4 months $ 7,080
"Cl
0) Fuel $ 50 per tank 32 tanks $ 1,600 <C
(1) $ 16,795 .....
0
8. Including Sage's Indirect Bu rden $ 18,475 .....
"'
m )> -o
Q) ::;· a
Sage -ODCs ~ o ro ~ C u,
:, OJ (ll
;o = 5 · TVAs (2) w/ dilution probes ($225/week) for 16 weeks $ 3 ,600 ~~~
; [g, Cal Gases ($50/week for 3 weeks) $ 150
g. ":' s. Dataloggers (2) ($50/week for 16 weeks) $ 800
G') ,., () IR Camera (2) ($1625/week for 16 weeks) $ 26 ,000
as·~ Hi Fl ow Sampler (2) ($360/week fo r 16 weeks). $ 5 ,760 c ~o
'C ~ 0 Propane (1 at $125) $ 125
3" 0 ~ Gas Regulato r (1 at $250) $ 250
() ~ OJ
. " () Nitrogen+Regulator+D olly $ 550 -o-
ii, Hard D rives $ 550 :,
Misc. Su pplies $ 200
Sample Capture (100@ $75/each) optional
$ 37,985
Including Sage's Indirect Bu rden $ 41 ,784
Sage -Analytica l Subcontract
Canister Analyses ($400/ca n x 45 cans) $ 18,000
Shipping ($100/shipment) $ 400
$ 18,400
Including Sage's Indirect Burden $ 20 ,240
H icks -Travel & ODCs
Fie ld Work
Lodging ($1,925/month x 2 months , accommodates 3 staff members) $ 3 ,850
Mileage (18 RTs x 450 miles x $.50/mile) $ 4 ,050
FedEx , supplies , equipment $ 1,000
$ 8 ,900
ERG PROPRIETARY IN FORMATION
This page intentionally left blank
Professional Serv ices Contract
Air Quality Study -Final Work Plan
Eastern Research Group , Inc . Page 72 of 73
SIGNATURE PAGE
CONTRACT FOR PROFESSIONAL SERVICES
DEM : 10-05 -NATURAL GAS AIR QUALITY STUDY
FINAL WORK PLAN
IN WITNESS THEREOF , the parties hereto have made and executed this Agreement in
multiple originals the day and year first above written , in Fort Worth , Tarrant County ,
Texas .
CITY OF FORT WORTH:
<z-ffel.:'*' a _
Fernando Costa
Assistant City Manager
APPROVED AS TO FORM AND
LEGALITY :
a;;Lh~
Arthur N. Bashor
Assistant City Attorney
Professional Services Contract
Air Quality Study -Final Work Plan
Eastern Resea rch Group , Inc .
EASTERN RESEARCH GROUP , INC .
Jo~
Vice President
Seal :
0Ffil81Al. . liCORD
CITY ICRITARY
FT.WO TH, TX
Page 73 of 73
.. _,..--
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--INSURANCE
--AND
-
-BONDS
-
CONTRACTOR COMPLIANCE WITH
WORKERS' COMPENSATION LAW
Pursuant to V.T.C.A. Labor Code §406.96 (2000), as amended , Contractor certifies that it
provides workers' compensation insurance coverage for all of its employees employed on
City of Fort Worth Department of Environmental Management Project DEM 10-05:
NGAQS-Natural Gas Air Quality Study Final Work Plan.
CONTRACTOR
EASTERN RESEARCH GROUP, INC.
Title
sTATE oF )l~llulse.ilS~ §
couNrv oF MJddle0&f< ~
me, the undersigned authority, on this day personally appeared
---1.Ja.".b~~~~~~.1 known to me to be the person whose name is subscribed to the
d acknqwledged to me that he executed the same as the act and
_.J..J.~~~L.,~:::t:'.~~~::='..._ _________ fo r the purposes and
consideration therein expressed and in the capacity therein stated.
Given Under My Hand and Seal of Office this J..!i day of r-~-"----
o ary Publi~j{l ~J1 c! for _ / _ ..LJ.--
e State of -Y'~~ ---------
~ GAIL SCHUBERT ® Notary Public
COMMONWEALTH OF MASSACHUSETTS
My Ccmm1ulon hplr•• Mcrch at , 2014
Parl tb. 10~.38651
THE STATE OF TEXAS
COUNTY OF TARRANT
PERFORMANCE BOND
§
§
§
KNOW ALL BY THESE PRESENTS:
That we, (1) EASTERN RESEARCH GROUP, INC., a Massachusetts corporation,
as Principal herein, and (2) 1ravelers Casualty arrl &11:ety Caq:a:1y of AIErica a
corporation organized under the laws of the State of (3) Can::ct.icut , and who 1s
authorized to issue surety bonds in the State of Texas, Surety herein, are held and firmly bound
unto the City of Fort Worth, a municipal corporation situated in Tarrant, Denton, Parker and
Wise Counties, Texas, Obligee herein, in the sum of Six Hundred Thousand Dollars
($600,000.00) for the payment of which sum we bind ourselves, our heirs, executors,
administrators, successors and assigns, jointly and severally, firmly by these presents .
WHEREAS, Principal has entered into a certain written contract with the Obligee dated
the __ day of , 20_, a copy of which is attached hereto and made a part
hereof for all purposes, for professional services to be performed for the City of Fort Worth
Air Quality Study as described in City of Fort Worth Council Resolution Number 3866,
City of Fort Worth Request for Qualifications DEM 10-05: NGAQS -Natural Gas Air
Quality Study Final Work Plan.
NOW, THEREFORE, the condition of this obligation is such, if the said Principal shall
faithfully perform the work in accordance with the plans, specifications, and contract documents
and shall fully indemnify and hold harmless the Obligee from all costs and damages which
Obligee may suffer by reason of Principal's default, and reimburse and repay Obligee for all
outlay and expense that Obligee may incur in making good such default, then this obligation
shall be void; otherwise, to remain in full force and effect.
PROVIDED, HOWEVER, that this bond is executed pursuant to Chapter 2253 of the
Texas Government Code, as amended, and all liabilities on this bond shall be determined in
accordance with the provisions of such statute, to the same extent as if it were copied at length
herein.
IN WITNESS WHEREOF, the duly authorized representatives of the Principal and the
Surety have executed this instrument.
SIGNED and SEALED this ___ day of __________ , 20_.
EASTERN RESEARCH GROUP, INC.
PRI ~
By: ~
(Principal) ~cretaFy VP .J.. Cini/io/{e, Name: John Eyraud
Title: Vice President
(SEAL)
ATTEST:
(SEAL)
NOTE:
Address: 110 Hartwell Avenue
Boston, MA 02421
SURET
By:_--+¥-""<..:,.____,i-+-~~--+--
Name: El.1m J.
Attorney-in-feet
(1)
(2)
(3)
Address: 3.:0 Grau.te Street
Suite Ia)l
&aintree, M\ 02184
Telephone Number: .'.DH)a)-3421
Correct name of Principal (Contractor).
Correct name of Surety.
State of incorporation of Surety
Telephone number of surety must be stated. In addition, an original copy of
Power of Attorney shall be attached to Bond by the Attorney-in-Fact.
The date of bond shall not be prior to date of Contract.
Parl fu. 105438651
THE STATE OF TEXAS
COUNTY OF TARRANT
PAYMENT BOND
§
§
§
KNOW ALL BY THESE PRESENTS:
That we , (1), EASTERN RESEARCH GROUP, INC., a Massachusetts corporation
as Principal herein, and (2) TI:avelers Casu:tl.ty arrl Surety Carpmy of luerka a
corporation organized and existing under the laws of the State of (3) Chp:ctjq rr; as
surety, are held and firmly bound unto the City of Fort Worth, a municipal corporation situated
in Tarrant, Denton, Parker and Wise Counties , Texas, Obligee herein, in the amount of Six
Hundred Thousand Dollars ($600,000.00) for the payment whereof, the said Principal and
Surety bind themselves and their heirs, executors , administrators, successors and assigns , jointly
and severally, firmly by these presents :
WHEREAS , the Principal has entered into a certain written contract with the Obligee
dated the __ day of , 20_, which contract is hereby referred to and
made a part hereof as if fully and to the same extent as if copied at length, for the following
project: professional services to be performed for the City of Fort Worth Air Quality Study
as described in City of Fort Worth Council Resolution Number 3866, City of Fort Worth
Request for Qualifications DEM 10-05: NGAQS -Natural Gas Air Quality Study Final
Work Plan.
NOW, THEREFORE, THE CONDITION OF THIS OBLIGATION IS SUCH, that if the
said Principal shall faithfully make payment to each and every claimant (as defined in Chapter
2253, Texas Government Code, as amended) supplying labor or materials in the prosecution of
the work under the contract, then this obligation shall be void; otherwise, to remain in full force
and effect.
PROVIDED, HOWEVER, that this bond is executed pursuant to Chapter 2253 of the
Texas Government Code, as amended, and all liabilities on this bond shall be determined in
accordance with the provisions of said statute, to the same extent as if it were copied at length
herein.
IN WITNESS WHEREOF, the duly authorized representatives of the Principal and the
Surety have executed this instrument.
SIGNED and SEALED this ___ day of __________ , 20_.
EASTERN RESEARCH GROUP, INC. :~INCi~~
(Principal)~ecretary-VP -J.. Con +liol/e,r Name : John Eyraud
Title: Vice President
Address: 110 Hartwell Avenue
Boston, MA 02421
'Itavelers Casu:llty arrl Surety,-Cmµmy of .4rErica
SURETY
ATTEST:
~mt~
~ ElJm M. Ibl.an
Att:arrey-in-fa::t
(SE AL) Address: .35J Gtari.te Street
Suite m
NOTE :
Braintree, M\ 02184
Telephone Number: ~.J'.'.i.21
(1)
(2)
(3)
Correct name of Principal (Contractor).
Correct name of Surety.
State of incorporation of Surety
Telephone number of surety must be stated. In addition, an original copy of
Power of Attorney shall be attached to Bond by the A ttomey-in-Fact.
The date of bond shall not be prior to date of Contract.
~ ·TRAVELERS J
WARNING: THIS POWER OF ATIORNEY IS INVALID WITHOUT THE RED BORDER
POWER OF ATTORNEY
Attorney-In Fact No.
Farmington Casualty Company
Fidelity and Guaranty Insurance Company
Fidelity and Guaranty Insurance Underwriters, Inc.
Seaboard Surety Company
St. Paul Fire and Marine Insurance Company
2 1888 1
St. Paul Guardian Insurance Company
St. Paul Mercury Insurance Company
Travelers Casualty and Surety Company
Travelers Casualty and Surety Company of America
United States Fidelity and Guaranty Company
Certificate No. Q Q 2 § 513 4 9
KNOW ALL MEN BY THESE PRESENTS : That Seaboard Sure ty Company is a corporation dul y organized under th e laws of th e St ate of New Yo rk , th at St. Paul
Fire and Marine In surance Company, St. Paul Guardian In surance Company and St. Paul Mercury In surance Company are corporations dul y organized under th e laws
of the State of Minnesota, that Farmington Casualty Company, Travelers Casua lt y a nd Surety Company, and Trave lers Casualty a nd Surety Com pan y of America are
corporations duly organ ized under the law s of the State of Conn ec ti c ut, th at United State s Fidelity a nd Guaranty Company is a corporation duly organized under th e
laws of the State of Maryland, that Fidelity and Guaranty In surance Company is a corporation dul y organized unde r th e laws of the State of Iowa, an d that Fidelity and
Guaranty In suranc e Underwriters , lnc . is a corporation dul y organized under th e laws of the State of Wi scons in (he re in collectively cal led th e "Compa ni es"), and th at
the Companies do hereby make, constitute and appoint
Frank J. Smith , Do nn a M . Robi e , Will ia m J . Do bbin s Jr., Christin a D. Hi cke y , Eilee n M. Ry an, Ell e n J . Yo ung , and Ell en M. Do lan
of the City of Nat ick , State of Massachusetts , their tru e and la wful Attorney(s)-i n-Fact,
each in their separate capacity if more than one is named above , to sign , exec ute , seal and acknow ledge any and a ll bonds, recog ni za nces, conditi o nal undertakin gs and
other writing s obli gatory in the nature th ereof on behalf of the Companies in their l;/u siness of g uaranteein g th e fidelit y of persons, guaranteein g th e pe1form ance of
contracts and executin g or guaranteei ng bond s a nd undert aki ngs required o r permitted in any-actio ns or proceedin gs all owed by law.
5th IN WITNE SS WHEREOF, the Compani es have caused thi s instrument to be sig ned and their co rporate seals to be hereto a ffi xed, thi s __________ _
d f Augus t -2008 " ' ay o
State of Connecticut
City of Hartford ss.
Farmington Casualty Company
Fidelity and Guaranty Insurance Company
Fidelity and Guaranty Insurance Underwriters, Inc.
Seaboard Surety Company
St. Paul Fire and Marine Insurance Company
By:
St. Paul Guardian Insurance Company
St. Paul Mercury Insurance Company
Travelers Casualty and Surety Company
Travelers Casualty and Surety Company of America
United States Fidelity and Guaranty Company
5th Aug ust On this the ________ day of ___________ _ 2008 · ____ , before me personally appeared George W. Thompso n, who ac kn ow ledged him self
to be the Senior Vice President of Farmington Casualty Com pan y, Fide lity and Guaranty In surance Company, Fidelity and Guaranty In sur ance Un de rwrit ers, In c .,
Seaboard Surety Company, St. Paul Fire and Marine In surance Company, St. Paul Guardian In surance Company, St. Paul M erc ury In surance Company, Travelers
Casualty and Surety Company, Travelers Cas ualty and Surety Company o f America, and Un it ed States Fidelity and Guaranty Company, and that he, as such, being
auth orized so to do , executed the foregoing in strument for the purposes therein contained by signin g o n behalf of th e corporation s by him se lf as a dul y a utho ri zed o fficer.
In Witness Whereof, l hereunto set my hand and official sea l.
My Commission expires th e 30th day of June , 2011.
58440-5-07 Printed in U.S.A.
'-Mari e C. Tetrea ult. No tary Public
WARNING: THIS POWER OF ATIORNEY IS INVALID WITHOUT THE RED BORDER
WARNING: THIS POWER OF ATTORNEY IS INVALID WITHOUT THE RED BORDER
This Power of Attorney is granted under and by the authority of the following re solution s adopted by the Boards of Directors of Farmington Casualty Company, Fidelity
and Guaranty Insurance Company, Fidelity and Guaranty Insurance Underwriters , lnc., Seaboard Surety Company, St. Paul Fire and Marine Insurance ('.0111Pat1Y,,.
St. Paul Guardian Insurance Company, St. Paul Mercury Insurance Company, Travelers Casualty and Surety Company, Travelers Casualty and Surety Company of
America , and United States Fidelity and Guaranty Company, which resolution s are now in full force and effect, reading as follows:
RESOLVED , that the Chairman , the President , any Vice Chairman , any Executive Vice President , any Senior Vice President, any Vice President, any Second Vice
President , the Treasurer, any Assistant Treasurer, the Corporate Secretary or any Assistant Secretary may appoint Attorneys-in-Fact and Agents to act for and on behalf
of the Company and may give such appointee such authority as hi s or her certificate of authority may prescribe to sign with the Company 's name and seal with the
Company's seal bonds, recognjzances , contracts of indemnjty, and other writings obligatory in the nature of a bond , recognizance, or conditional undertaking , and any
of said officers or the Board of Directors at any time may remove any such appointee and revoke the power given rum or her; and it is
FURTHER RESOLVED , that the Chairman , the President , any Vice Chairman, any Executive Vice President, any Seruor Vice President or any Vice President may
delegate all or any part of the foregoing authority to one or more officers or employees of this Company, provided that each such delegation is in writing and a co py
thereof is filed in the office of the Secretary ; and it is
FURTHER RESOLVED , that any bond , recognizance, contract of indemnity, or writin g obligatory in the nature of a bond , recognizance, or conditional undertakin g
shall be valid and binding upon the Company when (a) signed by the President, any Vice Chairman, any Executive Vice President, any Senior Vice President or any Vice
President, any Second Vice President , the Treasurer, any As sistant Treasurer, the Corporate Secretary or any Assistant Secretary and duly attes ted and sealed with the
Company 's seal by a Secretary or Assistant Secretary; or (b) duly executed (under seal, if required) by one or more Attorneys-in-Fact and Agents pursuant to th e power
prescribed in his or her certificate or their certificates of authority or by one or more Company officers pursuant to a written delegation of a uth ority ; and it is
FURTHER RESOLVED , that the signature of each of the following officers : President, any Executive Vice President, any Senior Vice President, any Vice President,
any Assi stant Vice President, any Secretary, any Ass istant Secretary, and the seal of the Company may be affixed by facsimj le to any power of attorney or to any certificate
relating thereto appointing Resident Vice Presidents , Resident Assistant Secretaries or Attorneys-in-Fact for purposes only of exec uting and attesting bonds and
undertakings and other writings obligatory in the nature thereof, and any such power of attorney or certificate bearing such facsimjle signature or facsimjle seal shall be
valid and binding upon the Company and any such power so executed and certified by such fac simile signature and facsimjle seal shall be valid and binding on the
Company in the future with respect to any bond or understanding to which it is attached.
I, Kori M. Johanson , the undersigned, Assistant Secretary, of Farrungton Casualty Company, Fidelity and Guaranty Insurance Company, Fidelity and Guaranty Insurance
Underwriters , Inc., Seaboard Surety Company, St. Paul Fire and Marine Insurance Company, St. Paul Guardian Insurance Company, St. Paul Mercury Insurance
Company, Travelers Casualty and Surety Company, Travelers Casualty and Suret}' Company o(America, and Uruted States Fidelity an d Guaranty Company do hereby
certify that the above and foregoing is a true and correct copy of the Power of ,:\ttomey executed by said Companies, which is in full force and effect and has not been
revoked .
IN TESTIMONY WHEREOF, I have hereunto set my hand and afl\xed the seals of said Companies this ___ _
0 ~
Kori M. Johans
-------~-_,20
To verify the authenticity of thi s Power of Attorney, call 1-800-421-3880 or contact us at www.travelersbond.com. Please refer to the Attorney-In-Fact number, the
above-named individuals and the detail s of the bond to which the power is attached.
WARNING: THIS POWER OF ATTORNEY IS INVALID WITHOUT THE RED BORDER
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REQUEST FOR
QUALi FiCA TIONS
'-ERG
Eastern Research Group, Inc .
PROPOSAL IN RESPONSE TO
REQUEST FOR QUALIFICATIONS PACKAGE (RFQ)
NO. DEM 10-05: NGAQS
AIR QUALITY STUDY
Submitted to :
City of Fort Worth
Department of Environmental Management
1000 Throckmorton Street
Fort Worth , TX 76102-6311
Submitted by:
Eastern Research Group, Inc.
1600 Perimeter Park Drive , Suite 200
Morrisville , NC 27560
with
Sage Environmental Consulting, LP
4611 Bee Caves Road , Su ite 100
Austin , TX 78746
June 2 , 2010
www.erg.com
ERG No. 0023 .00.002 .119
PROPOSAL IN RESPONSE TO
REQUEST FOR QUALIFICATIONS PACKAGE (RFQ)
NO. DEM 10-05: NGAQS
Al:R QUALITY STUDY
Submitted to :
City of Fort Worth
Department of Environm ental Management
1000 T hro ckmorton Stre et
Fort Worth, TX 76102 ~6311
Submitted by:
Eastern Research Group, Inc.
1600 Perimeter Park D riv e , Suite 200
Morrisville, NC 27560
with
Sage Environmental Consulting,., LP
4611 Bee Caves Road , Su ite 100
Austin, TX 78746
June 2 , 20 10
Air Quality Study June 2, 2010
CONTENTS
Section Page
1.0 QUALIFICATIONS DOCUMENTS
2.0 ACKNOWLEDGEMENT OF RECEIPT OF ADDENDA
3.0 MINORITY AND WOMEN BUSINESS ENTERPRISES (M/WBE) UTILIZATION
REQUIREMENTS
4.0 QUALi FICA TIONS OF THE PROVIDER ....................................................................... I
A. COMPANY INFORMATION .................................................................................... I
B. STATEMENT OF QUALIFICATIONS .................................................................... 2
8.1 Ambient Air Sampling, and Related Laboratory Analysis and QA/QC
Experience ......................................................................................................... 2
8 .2 Point Source and Equipment Emissions Testing, and Related Laboratory
Analysis and QA/QC Experience ..................................................................... 4
8.3 Clean Air Act Experience Related to Natural Gas Production ......................... 5
8.4 Dispersion Modeling Experience ...................................................................... 5
8.5 Project Organization and Management ............................................................. 8
8.6 Personnel Qualifications ................................................................................. 11
8.7 Laboratories and Accreditations ..................................................................... 15
8.8 Disclosures ...................................................................................................... 15
C . SCOPE OF SERVICES: METHODOLOGY AND WORK PLAN ......................... 16
Task A: Measure and Analyze Emissions ................................................................ 17
Task B: Conduct Dispersion Modeling ..................................................................... 21
Task C: Conduct Ambient Sampling ........................................................................ 22
Task D: Develop Communication Plan .................................................................... 24
5.0 LIST OF SUBCONTRACTORS
6.0 INSURANCE CERTIFICATES
7 .0 PROVIDER'S LICENSES AND CERTIFICATES
8.0 NONDISCRIMINATION
9 .0 CONFLICT OF INTEREST AFFIDAVIT
ATTACHMENT A: KEY STAFF RESUMES
ATTACHMENT B: SAMPLE DOCUMENTS
'1:RG
Air Quality Study June 2, 2010
CONTENTS (Continued)
Tables Page
l Selected Ambient Air Sampling, and Related Laboratory Analysis and QA/QC Experience 3
2 Selected Point Source and Equipment Emissions Testing, and Related Laboratory
Analys is and QA/QC Experience ............................................................................................ 6
3 Selected Clean Air Act Natural Gas Production Experience ................................................... 7
4 Selected Dispersion Modeling Experience .............................................................................. 9
5 Summary of ERG Team Key Personnel Qualifications ........................................................ 11
6 Project Milestones and Planned Schedule ............................................................................. 18
7 Example Point Source Sample Matri x ................................................................................... 20
Figures Page
ERG Team Project Organization ........................................................................................... 10
II
1.0 QUALIFICATIONS DOCUMENTS
QUALIFICATIONS DOCUMENT CHECKLIST
All Qualifications Documents, incl uding this Checklist. must be completed in full and
submitted in a sealed envelope, in the requested order, or the Qualifications Package may
be considered as a non-responsive submitta l.
Qualifications Documents Initial if In cluded
1 .
2 .
3 .
4 .
5 .
6 .
7 .
8 .
9 .
QUAUFICATIONS DOCUMENT CHECKLIST
ACKNOWLEDGEMENT OF RECEIPT OF ADDENDA
MINORITY and WOMEN BUSINESS ENTERPRISES
QUALIF I CATJONS OF PROVIDER
LIST O F SUBCONTRACTORS
INSURANCE CERTIFICATES
PROVIDER 'S LICENSES & CERTIFICATES
NONDISCRIMINATION
CONFLICT OF INTEREST AFFADAVJT
I understand that failure to submit all of these item s may cause my submittal to be considered non-responsive.
Name
Tltle
Paula G. Fields
Principal Engineer
Company --""'E=a=st=e'""'m"-'R-"e=s=e=arc""'·"-'-h-=GC'-'ro=u=p'-'-, "'"'ln=c.'--'(=E'-'R=G_._) _
2.0 ACKNOWLEDGEMENT OF RECEIPT OF ADDENDA
2 .2.1 Check if applicable _x_
The undersigned acknowledges the receipt of the following addendum (a) to the Request for
Qualifications , and has attached all addenda following this page. (Add lines if necessary).
Addendum Number 1 _____ 5/=-=-14..:.:../..:..:10=-------
(Date rece ived)
Addendum Number 2'-____ 5=/'2=5/=--c..c1 O=--'("-'re'-'-v."-'. 512=6/~1~0~) _
(Date received)
Addendum Number 3 ___________ _
(Date rece ived)
Addendum Number4 ___________ _
(Date received)
2 .2 .2 Check if appli cable_
The undersigned acknowledges the re ceipt of no addenda to the Request for Qualiffcatlons .
PROVIDER:
Eastern Research Group. In c. BY: Paula G. Fields
Company Name (print or type name of signatory)
8950 Cal Center Dr.. #348 ~~.~ (Signature Address
Sacramento, CA 95826 Principal Eng in eer
City, State , Zip Trtle (print or type)
3.0 MINORITY AND WOMEN BUSINESS ENTERPRISE (MIWB E)
UTILIZATION REQUIREMENTS
An M/WBE goal of 10°/o has been established for this project.
The Provider shall make a good faith effort to sub-consult with or purchase supplies from
M/WBE firms . T h e P r ovi der must meet or exceed the stated goat or subm it
documentation of a good faith effort for al.I applicab le contracts to permit a determination
of compliance w ith the specifications .
Because this is a Request for Qualifications for professional services defined In C hapter
2254 of the Texas Govern ment Code. the Provider's initi al response t o the Req uest for
Q ualifications sha ll n ot i nclu de a response to the requ irements of the C ity's M/VVBE
ordinance. Th e City sha ll r ank the Provider on t h e basis of demonstrated competence
and qualifications. During contract negotiations , t he Provi der shall respond to t h is
ordinance in the manner specified be low:
(1) An M/WBE Utilization P lan , hereinafter referred to as t he utilization pla n. m ust be
submitted. The uti lization plan must detail the st eps taken to achieve M/WBE
parti cipation including but not li m ited to firms contacted , type of work d iscussed .
criteria for sub-contractor selection , etc. The utili zation plan must address each
subcontracting opportun ity available that may include p r ofess ional services .
subsurface drilling/boring , courier service , outside print in g , equ ipment suppli ers.
etc.
(2) The utilizati on p lan must also include the po int o f con tact (including name and
title) that wm be designated as responsible for implementing the utilization plan .
reporting on the status of utilization plan (monthly and ann u all y), and performing
liaison dut ies to t he C ity as it relates to all MNJBE issues during the contract
term .
(3) The Prov ider may utili ze a j oint venture arrangement wi t h an M/WBE firm . ln a
j oint venture, t h e Prov ider may count the M/WBE portion of the joint ventu re
toward meeting the utilization plan comm itment (i.e .. proposed goal is 40% an d
j oint venture is 20% t hen separate M/WBE m u st be used for the remain ing 20 %
not for the entire 40%). If a joint venture is proposed , the Joint Venture Elig ibility
Form must be completed and submitted.
(4) All M/WBE firms must be currently certified or i n t he process of be ing certifi ed by
the North Central Texas Reg ional Certification Agency (NCTRCA), or Texas
Department of Transportation (TXDOD , Highway Division and located in t he nl ne
county marketplace. For the purpose of deter m ining contract compli an c e under
the M/VVBE o rd inance, businesses listed as MBE or WBE w ithin the ut ili zatio n
plan must be certified as such prior to a recommendation for award being made to
the City Counci l. If during the course of work u nder the contract a c hange of a ny
of the MBE o r WBE firms identified in the orig inal utili za ti on plan is needed then a
Change Request must be submitted to the C ity of Fort Worth -MNJBE Office a nd
the change approved by same.
{5) All subcontracting and supplier opportunities directly attributed to this Contract
from M/WBE firms , i nclus ive of 1st , 2nd , 3rd tiers , etc . sub-contractors and suppliers
may be included in the utilization plan commitment. It is the sole resp ons ibility of the
Prov ider to report and document all M/WBE partici pation dollars irrespective of tler
level. The Provider w ill be g iven credit toward the M/WBE plan when the M/WBE
performs a commerci ally useful function. The successful Provider will be requ ired to
submit executed contractua l agreements (i.e., Master Serv ice Agreements) or letters of
i ntent prior to rece iving the Contract Documents.
The undersigned acknowledges the City's MM/BE requ irements as stated above, and if selected as
the most high ly qualified provider. will comply with the requ irement to submit a util ization plan during
contract negotiat ions.
PROVJDER:
Eastern Research Group, Inc.
Company Name
8950 Cal Center Dr:. #348
Address
Sacramento. CA 95826
City . State, Zip
BY : Paula G, Fields
(print or type name of signatory)
(-~~.~
(Signatt(
Principal Eng ineer
Title (print or type)
Air Quality Study June 2, 2010
4.0 QUALIFICATIONS OF THE PROVIDER
A. COMPANY INFORMATION
This proposal is submitted by the team of Eastern Research Group, Inc. (ERG) and Sage
Environmental Consulting, LP (Sage). Addresses and contact information follow:
Headquarters: Key Contact
110 Hartwell Ave., Lexington , MA 02421 Person:
\\ERG Key Contributing Offices: Mike Pring
• 3508 Far West Blvd ., Suite 210, Austin, TX 78731 Project Manager
• 1600 Perimeter Park Dr., Suite 200, Morrisville, NC 919-468-7840
27560 Mike.Pring@ erg .co
• 8950 Cal Center Dr., Suite 348, Sacramento, CA 95826 m
Headquarters: Key Contact
720 W. Arapaho Road , Richardson, TX 75080 Person:
Key Contributing Offices: David Ranum
SAGE •4611 Bee Caves Rd., Suite JOO, Austin , TX 78746 Senior Technical ltN VlilltOH IHl'tT,oL. CON.U..TING
~f'rl.,,,ll7&mt:e.NoS..l"pl'Uu!N • 12727 Featherwood Dr., Suite 210, Houston , TX 77034 Specialist
• 1401 South County Rd. 1140 , Midland, TX 79706 512-327-0288
davidr@sage enviro
nmental. co m
ERG is a Massachusetts Corporation that provides environmental , engineering, economic, and
laboratory services to primarily federal , state, and local government agencies. ERG's clients
include: the U.S. Environmental Protection Agency (U.S . EPA); and the Departments of Labor
and Department of Energy. We work for many state and local air agencies, including the states of
Texas, Louisiana, and Arkansas; and organizations in Houston , Austin, Sacramento, and
el sewhere. Our clients also include regional organizations such as the Western Regional Air
Partnership (WRAP), and the Western Climate Initiative (WCI). ERG has extensive knowledge
of the natural gas exploration and production industry from our regulatory development, air
toxics, and air permitting projects for government agencies. We have performed air quality
studies comprising all of the elements involved in the City of Fort Worth's (City 's) natural gas
air quality study (NGAQS): source sampling and characterization , dispersion modeling,
emissions estimating, ambient air sampling, laboratory analyses, and health risk assessments.
Sage Environmental Consulting, L.P. (Sage) is an environmental engineering and consulting
company with expertise in regulatory compliance and permitting. Sage provides services across a
wide spectrum of environmental programs and media such as air quality , hazardous and solid
waste, water quality , hazardous materials, and petroleum storage activities. While Sage provides
a broad range of services, its specialty is the air quality aspects of heavy process industries
especially petroleum refining, chemical manufacturing, and upstream and midstream oil and gas
operations. As a subcontractor, Sage will evaluate point source and equipment emissions
generated from natural gas facilities in Fort Worth. Sage will provide input to all tasks related to
source testing and analysis, and may assist with dispersion modeling of selected sites.
Also, ERG has identified a properly accredited and highly qualified Minority/Woman Owned
Business Enterprise (M/WBE), with an office in Fort Worth , and with whom Sage has a strong
working relationship in the areas of source sampling and public outreach. We will quickly add
Air Quality Study June 2, 2010
them to our team during negotiations and commit no les s than I 0% of the project budget to their
efforts, anticipated to be in the source sampling and communications planning areas.
B. STATEMENT OF QUALIFICATIONS
The ERG/Sage team collectively has the best technical and communications skills to successfully
plan and implement the NGAQS for the City:
• Availability -We are strong in numbers and deep in experience. Our key staff are available
to kick off the project and begin source testing in August.
• Natural gas sector experience -We are experienced in characterizing, sampling, and
modeling emissions from the range of gas field sources . Our staff work within these
industries on behalf of regulators , including those located within the Barnett Shale. We have
demonstrated our abilities to communicate effectively under these conditions.
• No conflict of interest -As a company, ERG does not conduct any environmental ,
regulatory , or permit application support work for private industrial companies. While Sage
does have direct industry experience, natural gas producers represent less than 5% of Sage
revenues over the last three years. The ERG/Sage team has the ability to objectively perform
the project activities while holding the best interests of the City and its citizens paramount.
• Reputation for high quality and technical knowledge -Just ask our clients! We regularly
work for federal , state, local , and regional government agencies to address a wide range of air
quality issues. Our technical skills have earned us a reputation for meeting technical
challenges, producing high quality reports , and delivering on time and within budgets. Most
of our clients are repeat customers.
The remainder of this section describes the qualifications of our team within the main areas
necessary for this project: ambient sampling, emissions testing, dispersion modeling, and
communications/outreach. This experience is all primarily focused on air toxics emissions
emitted by the gas or related industries.
8.1 Ambient Air Sampling, and Related Laboratory Analysis and QA/QC
Experience
The ERG team supports clients ' measurements and monitoring programs from design and
planning, through execution , to the interpretation and effective presentation of results . Table I
presents selected examples of past experience of ERG in the area of ambient air sampling of
to x ic pollutants and related laboratory analyses and QA/QC activities. Our team includes
chemists, environmental scienti sts, mechanical engineers, and highly trained technicians. We
have designed , managed , and operated national monitoring networks , and prepared associated
technical assistance documents for the U.S. EPA. We provide a turn-key approach to network
design beginning with the determination of data quality objectives (DQOs) continuing through to
data characterization and reporting.
For more than 20 years , the ERG team has sampled and analyzed millions of hazardous a ir
pollutant measurement records for federal , state, local , and tribal agency clients. As the prime
contractor for U.S. EPA 's Urban Air Toxics Monitoring Program (UATMP), ERG staff gained
unparalleled experience in collecting , analyzing, and characterizing air toxics measurements.
2
w
~ Table 1. Selected Ambient Air Sampling, and Related Laboratory Analysis and QA/QC Experience
;;:p ~-------------------.--------,
G) Client Contact, Value,
Proiect Scope
National Monitoring Programs (ERG). ERG is the prime contractor for U.S. EPA 's National
Monitoring Programs, a position held since the contract 's inception in 1984 . Over the last 26 years,
ERG staff have supported U .S. EPA , state, local , and tribal agencies in network design , siting,
methods development, sampling, analysis, and reporting of air toxics. Major programs include: the
Urban Air Toxics Monitoring Program (UATMP); Non-Methane Organic Compounds (NMOC);
Speciated NMOC (SNMOC); National Air Toxics Trends Sites (NA TIS); Community-Scale Air
Toxics Ambient Monitoring Program (CSA TAMP); and the Photochemical Assessment Monitoring
Stations (PAMS) support. In total, several hundred monitoring sites across the country have
participated in these programs. In the last five years, U .S . EPA has used this contract for emergency
response/time-sensitive applications for U .S . EPA , federal , and state/local/tribal agencies, such as for
monitoring after Hurricane Katrina. ERG is supporting U.S. EPA in its School Air Toxics Monitoring
Initiative, a program designed to address whether children at schools are being disproportionately
impacted from air toxic emission sources from nearby large manufacturing facilities . Currently , ERG
is assisting U.S. EPA and affected states in analyzing air toxic samples in response to a recent oil spill
in the Gulf of Mexico.
Agency for Toxic Substances and Disease Registry (ATSDR). ERG is the prime contractor for
ATSDR's air monitoring programs in a wide range of technical , scientific, and logistical areas of
exposure assessment, toxicological evaluations, public h~alth evaluations , community outreach
activities , training support, and other scientific evaluations. ERG has provided assistance to A TSDR
in all phases of planning and implementing exposure investigation environmental monitoring
programs resulting in the design of efficient and representative ambient air monitoring approaches.
Sampling of VOCs; carbonyl compounds; TSP mass ; TSP trace metals; continuous PM 10 and PM2 5 ;
and continuous S02, H2S, and /or NH3 to support agency exposure investigation efforts have occurred
in several locations around the country for intensive 2-3 month studies.
Stationary Sources Audit Program. Under this project, ERG manages the development and
distribution of QA performance evaluation and audit samples to states and regions for use in
stationary source compliance test evaluation projects. Al so under this project, ERG staff have
developed and improved sampling and analysis methods for toxic compounds on U .S. EPA 's high
priority list of 33 toxic chemicals.
Location, Period of
Performance (POP)
Mike Jones, U.S. EPA
(919) 541-0528
Valu e : $18 ,629 ,589
POP : 4/2009-9/2013
Debra Gable, A TSDR
(404) 498-0489
Value : $8 ,965 ,843
POP : 8/2005-8/2010
Jeffrey Curry, U.S. EPA
(919) 541-4018
Value: $500 ,000
POP: 12/2005-9/20 l 0
c...
C:
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C) .....
C)
Air Quality Study June 2, 2010
This experience has been critical in responding to emergency response/time-sensitive
applications for federal and state/local/tribal agencies, such as for monitoring after Hurricane
Katrina. Within one month of this devastating hurricane, ERG helped U.S. EPA, federal , and
affected state agencies design and implement a monitoring network of over 30 sites to address
potential health impacts during cleanup and recovery. ERG is currently assisting the U.S. EPA
and affected states in analyzing air toxic samples in response to the oil spill in the Gulf of
Mexico .
ERG has also supported the Agency for Toxic Substances and Disease Registry (A TSDR) air
monitoring programs in a wide range of technical , scientific, and logistical areas of exposure
assessment, toxicological evaluations, public health evaluations, community outreach activities,
training support, and other scientific evaluations. Currently, ERG is supporting U.S . EPA in its
School Air Toxics Monitoring Initiative, a program designed to address whether children at
schools are being disproportionately impacted by air toxic emissions from nearby manufacturing
facilities. For this program , ERG collects and analyzes selected air toxics for 59 schools ,
participates in stakeholder's meetings, and prepares technical reports on the measurements,
meteorology , and sources of interest.
8.2 Point Source and Equipment Emissions Testing, and Related Laboratory
Analysis and QA/QC Experience
ERG team member Sage offers technical expertise in the use of gas monitoring equipment for
the implementation of point source sampling programs. Sage understands oil and gas regulations ,
has exceptional sampling and monitoring capacity and experience, and a hands-on knowledge of
the industry. To characterize emissions from natural gas facilities and equipment, Sage provides :
• infrared (IR) cameras to help quickly identify major leaks;
• Toxic vapor analyzers (TV As) to provide direct concentration measurements; and
• Hi Flow samplers to provide direct on-site emission rate measurements.
Sage's experience related to oil and gas exploration and gas production has been in the major
producing regions of Texas, Louisiana, New Mexico, Colorado, Wyoming, and Montana. Over
20% of Sage 's historic and current workload has involved the measurement of benzene
emissions, and another 20% has involved measurement of fugitive emissions. For the City of
Corinth , Texas, Sage provided technical support to help the environmental staff understand the
TCEQ Effects Screening Levels (ESLs) and how they could impact residents near gas well
drilling operations. Sage's expertise with air quality sampling and monitoring spans a period of
40 years. A few examples of Sage staff's relevant sampling and monitoring experience follows:
• Sampling to support natural gas plant emission factor development;
• Sampling of wellhead emissions from steam enhanced secondary recovery operations;
• Design and installation of a vapor well monitoring system;
• [mplementation and management of a natural gas plant fugitive emission program;
• Set up and operation of LOAR program for a West Virginia gas plant;
• Compound specific sampling methods using gas chromatographs ;
• Ambient and source level sampling using FTIR (Fourier Transform [nfra-Red) analyses;
• Numerous gas canister sampling programs in ambient and source level applications; and
• Gas plant facility emissions surveys using the [R cameras and TVA 10008 analyzers.
4
Air Quality Study June 2, 2010
• Evaluation of the IR camera as a fugitive leak detector in a Texas refinery.
• Sampling to measure mass emissions from barges in transport.
• Design of sampling methods and led the sampling field work for the 14 refinery
Characte rization of A tmo spheric Emissions from Petrole um Refin eries , which developed the
prototype for U.S. EPA Method 21 and the format for the fugitive emissions correlation
equations and emission factors used today.
Table 2 presents selected examples of Sage 's past experience with oil and gas issues, including
data reporting, data management system preparation , sampling, and several other pertinent types
of projects for various facilities.
Analysis of samples collected by Sage will be conducted by TestAmerica, Austin Laboratory.
Information on TestAmerica is provided in Section B.7, below .
8.3 Clean Air Act Experience Related to Natural Gas Production
The ERG team has supported federal , state, and local air pollution control agencies in
implementing the provisions of the Clean Air Act (CAA) for over 28 years. Our experience in
this area includes directly supporting the U.S . EPA in implementing Title I of the CAA by
developing New Source Performance Standards (NSPS) and National Emission Standards for
Hazardous Air Pollutants (NESHAP), by compiling the National Emissions Inventory (NEI) and
the urban air toxics inventories required by Sections 112(k) and 112(c)(6), and by developing
county-specific air toxics hot spot emission inventories under the National Air Toxics
Assessment (NAT A) program.
ERG has worked with numerous state and local agencies in implementing the permitting
provisions of Title I (New Source Review) and Title V (Operating Permits) of the CAA in
issuing over 1,700 air quality permits, many of which were for natural gas exploration ,
production , and processing facilities.
In addition , team member Sage, has relevant experience in natural gas production federal
regulatory is s ues. For example, Sage performed a SIP and nonattainment evaluation study for
sulfur dioxide (S02) in Oklahoma. The project required compiling the emissions inventory and
performing dispersion modeling to successfully avoid a proposed S02 nonattainment designation
request by U.S. EPA. Also , Sage has performed numerous permitting projects for oil and gas
companies.
Table 3 presents several relevant examples of projects performed by the ERG team for
implementing provisions of the CAA for natural gas production sources.
8.4 Dispersion Modeling Experience
The ERG team includes expert meteorologi sts , engineers, and computer scientists who employ
state-of-the-art modeling procedures for complex, unique air pollution situations including
atmospheric photochemical reactions, health effects evaluations, hazardous pollutant releases ,
and complex meteorological phenomena. With more than 30 years of combined expert
dispersion modeling experience, ERG staff have conducted numerous studies of source impacts
in complex terrain, shoreline environments, and other areas where complicated dispersion
situations can be expected. ERG modeling staff have also developed computer programs and
procedures for processing large amounts of raw meteorological data in support of dispersion
5
Table 2. Selected Point Source and Equipment Emissions Testing, and Related Laboratory Analysis
and QA/QC Experience
Project Scope
Oil and Gas Technical Support for the City of Corinth TX (Sage). Sage personnel provided
technical support to help the environmental staff to better understand the air quality implications
of the TCEQ Effects Screening Levels and how they could impact residents near gas well drilling
operations . Sage also prepared SCREEN modeling to calculate from known emission rates of
benzene the ground level concentrations that could be expected at residential areas . This
information was provided to the city staff so they could better inform their City Council.
Infrared Imaging SEP (Sage). Sage staff performed a two part study us ing the infrared camera to
detect refinery process equipment leaks in Port Arthur, TX. In the first part of the study all
regularly monitored components in the refinery LDAR program were surveyed with the camera .
In the second part, equipment outside of the LOAR program was surveyed for leak emissions.
The study took 9 months to complete and resulted in the development of several practical camera
screening methodologies and produced informative conclusions regarding number of components
that could be effectively surveyed by the camera on a daily basis. The study also looked at the
effect of environmental factors such as wind , cloud cover, ambient temperature, % relative
humidity , barometric pressure, and types of imaging backgrounds on imaging quality.
IR Camera Survey at Natural Gas Liquid Separator Plant (Sage). Sage recently completed an
infrared camera survey of a liquid separator plant operated by Enterprise Products, in response to
odor complaints from a nearby neighbor. The survey was conducted by David Ranum and
included all equipment at the 400 million scfm facility . Several emission points were detected
with the camera by Mr. Ranum.
Measurement and Modeling of BTEX Emissions from Glycol Dehydrators for Gas Research
Institute (Sage). Sage staff led a project to develop new test methods for the measurement of
benzene/toluene/ethylbenzene/xylene (BTEX) emissions from glycol dehydrators. Assisted in the
development of the program with the GRI advisory review committee. Several methods were
tested in trials and the most favorable , (i.e., is the easiest to use and most accurate) methods were
further refined through extensive field testing. The final methods were documented through the
ASTM method development process .
Client Contact, Value,
Location, Period of
Performance (POP)
Bruce Hanson , City of
Corinth
(940) 321-1484
Valu e :$ 10 ,000
POP: 4/20l0-5/2010
Jannetta Bowden Ned , Total
Petrochemicals USA.
( 409) 963-6972
Value: $800 ,000
POP: 09 /2007-10/2008
Farah Ullah , Enterprise
Products
(713) 381-6500
Value : $4 ,000
POP: 3/2010
Gas Research Institute (GRI)
Valu e : $100 ,000
POP: 1992 c....
§
ct> _,....,
I\)
0 .....
0
Table 3. Selected Clean Air Act Natural Gas Production Experience
Client Contact, Value,
Location, Period of
Project Scope Performance (POP)
Texas Upstream Oil and Gas Emissions Inventory (ERG). ERG is developing a state-wide Greg Lauderdale, TCEQ
emissions inventory of upstream oil and gas sources associated with the onshore ex ploration and (512) 239-1433
production of oil and natural gas in Texas. First, we estimated criteria pollutant and HAP Valu e: $338 ,000 (2 contracts)
emissions from drilling rig engines . Currently, we are conducting surveys to collect emissions POP: 2/2009-8/2010
data from upstream oil and gas dehydrators , compressor engines, wellheads, oil/gas well
completions , pneumatic devices, turbines, storage tanks, equipment leaks , and loading racks .
Emissions estimates to include benzene, toluene , ethylbenzene, xylene, and formaldehyde.
Indiana Air Permit Review and Preparation Support (ERG). ERG supported the Indiana Duane Van Laningham, IDEM
Department of Environmental Management (IDEM) in air permit application reviews and (317) 233 -6878
preparation of permits to address application of federal and state requirements . Prepared over Value : $9 ,400 ,000 (2 contracts)
1,400 draft permits for a many industries and emission sources including natural gas compressor POP: 5/2000-1 2/2008
stations and processing plants, boilers, and reciprocating and internal combustion engines .
Alaska Air Permit Technical Assistance (ERG). ERG reviewed permit applications and drafted Debra Dalcher, Alaska
Title V Operating permits for 10 facilities (including 6 oil and gas platforms). ERG prepared one Department of Environmental
major NSR PSD permit for an oil and gas facility , and three BACT analyses for major NSR Conservation (ADEC)
permits for fuel gas souring on oil and gas platforms. Prepared statement of basis and final (907) 269-7562
decisions regarding applicability of state and federal regulations. Developed permit language and Value : $3 ,225 ,000 (2 Contracts)
reporting requirements to ensure compliance with all applicable state and federal air regulation s . POP: 5/2006-6/2010
Draft Air Quality Installation/Operating Permits Support (ERG). ERG is reviewing permit Sandra Etzel, Allegheny County
applications and drafting Minor Source Operating permits for over 150 individual sources, Health Department (ACHD)
including several natural gas compressor stations . ERG conducted on-site inspections of each (412) 578-8116
facility to confirm compliance with all applicable provisions of the Clean Air Act, and to obtain Value : $1 ,000 ,000
the data needed to prepare the emissions inventory. Conducted completeness reviews and POP: 4/2008-6/2010
prepared letters to the source to collect information not obtained during the site vis it.
Permit Preparation for the Navajo Nation (ERG). ERG staff prepared seven Title V Permits for Charlene Nelson , Navajo Nation
the Navajo Nation EPA including four El Paso Natural Gas Company Compressor Station s, the (928) 729-4247
APS Four Corners Steam E lectric Station (FCSES), the SRP Navajo Generating Station (NGS), Value : $93 ,000 (3 Contracts)
and the Peabody Western Coal Company Black Mesa Complex. POP: 912006 -3 /2009
'-§
(!)
-"' "' 0 ....
0
Air Quality Study June 2, 2010
modeling efforts. We also have extensivel y worked to develop, enhance, and apply air dispersion
models and modeling techniques to solve a multitude of air quality issues throughout the U.S., as
well as in Canada, Australia, Great Britain , Taiwan, Thailand, Azerbaijan , Argentina, Morocco ,
Qatar, and Saudi Arabia. To demonstrate the range of our capabilities, ERG staff have:
• Conducted dispersion modeling compliance assessments for hundreds of facilities throughout
the U.S., leading to the approval of required state and federal operating air permits;
• Performed deposition and air dispersion modeling in support of several public health
assessments, as well as assessments of proprietary diesel fuel additives, hazardous waste
incinerators, and trace element emissions by electric utilities;
• Assessed health risks of populations exposed to potentially harmful air emissions ; and
• Determined optimal site locations and design for new facilities to minimize air quality
impacts.
The ERG team has experience using many different dispersion models including: AERMOD,
ISCST3 , ISCL T3 , I SC-PRIME, CALPUFF, VISCREEN , OZIPM, RPMIJ , and RPMITSS. ERG
staff have also worked extensively with models specialized for dealing with complex terrain
(CTSCREEN , CTDMPLUS), mobile source impacts (CALINE/CAL3QHC), offshore impacts
(OCD), and accidental hazardous releases (CHARM). ERG's expertise in air quality modeling
includes modeling wet and dry deposition, visibility and regional haze, emergency response and
hazardous chemical releases, atmospheric chemistry, fugitive dust, offshore and coastal
dispersion , and long-range transport.
Many of our team 's modeling activities were in support of national emission standards for
hazardous air pollutants (NESHAPs), and state air quality permitting efforts, as well as ambient
monitor siting and exposure analyses. The ERG team has performed these modeling projects for
a variety of different facility types, including natural gas processing plants, crude oil processing
plants, power plants, refineries , and chemical manufacturing plants. Table 4 presents examples of
past modeling analyses performed by the ERG team.
8.5 Project Organization and Management
ERG 's project management plan is based on strong leadership in our project manager, Mr. Mike
Pring, and continual communications within the ERG team and between the team , the City, and
stakeholders throughout the contract term. We will convene team calls once every two weeks (at
minimum) and stay in close touch with the City. ERG has conducted government agency
contracts for nearly 25 years. We have in place the structure of experienced program managers,
contract administrators, administrative staff, and accounting systems needed to implement the
proposed contract from day one . Two important project considerations are meeting the interim
and overall deadlines, and ensuring high quality deliverables will be developed through effective
monitoring of schedules and quality.
Our project organization structure shown in Figure l facilitates effective communication of
technical data between the City and ERG , as well as among our Project Manager, Task Leaders
and key staff. This integrated approach provides the best combination of project management
and technical leadership because we use technical experts in Task Leader roles and a single
point-of-contact as our Project Manager. All of these staff have successfully completed similar
air quality studies for other clients. Note our commitment to add a properly accredited M/WBE
firm to the team , whom we have alread y identified.
-.ERG 8
Table 4. Selected Dispersion Modeling Experience
Project Scope
Alaska Air Permit Modeling Assistance (ERG). ERG assisted ADEC by reviewing the source
impact modeling analysis for a PSD permit issued for a major crude oil processing facility on the
North Slope of Alaska. ERG reviewed the applicant's AERMOD modeling demonstration to
verify that the proposed facility would be in compliance with the Alaska Ambient Air Quality
Standards and federal National Ambient Air Quality Standards for NOx, CO, S02, and PM JO.
Dispersion Modeling in Support of Indirect Risk Assessments of Hazardous Waste Combustors
at Six Industrial Facilities (ERG) ERG staff conducted air dispersion modeling for stack and
fugitive sources using ISCST3 in accordance with U .S. EPA's guidance "Human Health Risk
Assessment Protocol for Hazardous Waste Combustion Facilities". The air modeling included air
concentration of vapors and particulate , wet and dry deposition for particulate, and wet deposition
of vapors. Deliverables included ISCST3 input and output files; spreadsheets and software tools
used to determine input parameters ; and , reports with modeling results and QA/QC findings.
Regional Air Quality Modeling for Ras Lajfan Industrial City (ERG) ERG staff conducted a
regional air quality evaluation and planning for Ras Laffan Industrial City, Qatar, in conjunction
with the proposed expansion of a large , liquefied natural gas (LNG) plant. As well as other
subsequent expansions by Qatargas and International Power, activities included performing air
dispersion modeling selection , data gathering, and model application, as part of a comprehensive
Environmental Assessment (EA). Follow-on activities included a model evaluation study,
comparing modeling results obtained with ISCST3 and AERMOD.
Independent Third-Party Review of the ASARCO El Paso Smelter, Regulatory Assistance/or
the Panda Gila River Cogeneration Project (ERG) ERG staff conducted an independent audit of
ASARCO Incorporated 's air quality analysis performed in support of the renewal ofTCEQ Air
Permit 20345 for the El Paso Smelter. Served as an independent expert as part of an Interim
Agreed Order between ASARCO and TCEQ . Analysis included evaluating modeling techniques
using the AERMOD dispersion model , emission and meteorological data development, and
interpretation of results . Compounds consisted of criteria pollutants (S02, PM IO, NOx , CO), and
air toxic emissions subject to TCEQ Effects Screening Levels (ESLs).
Client Contact, Value,
Location, Period of
Performance (POP)
Debra Dalcher, ADEC
(907) 269-7562
Valu e: $35 ,000
POP: 4/2008-10/2008
Dr. Laurie C. Haws , TCEQ
(UT/CEER as Prime)
(512) 239-1789
Valu e : $48 ,400.00
POP: 11 /2002-9/2 003
Mr. Michael Snakard , URS
(713) 299-9149
Value: $46 ,000
POP: 08 /2002-05/2005
Robert Opiela, TCEQ
(Radian/URS as Prime)
(512) 239-1147
Value: $15 ,000
POP: 0 l/2007-06/2007
Figure 1. ERG Team Project Organization
FORT WORTH
~
Mike Pring (ERG)
ERG Project Manager,
M/WBE Monitor
Clin t Burk/in, PE (ERG) R egi Oommen (ERG)
Senior Peer Reviewe r QA/QC Coord inator
"
' ' Ir " 0
D avid Ran um (Sage) Arney Sra ckengast (ERG) D ave D ayton (ERG) J ohn Wilhelmi (ERG)
Task A Lead : Measure and Task B Lead : Task C Lead : Task D Lead :
Analyze E mi ssions Dispersion Mo de li ng Amb ie nt Samp li ng Comm unicat ion P lan
•
Key Support Staff: K ey Support Staff: Key Supp ort Staff:
Art Bedrosia n (Sage) Art Bedrosian (Sage) Ray Merri ll , Ph .D . (ERG)
Je nni fe r Pa rr as (Sage) Scott F incher (ERG) Reg i Oommen (ERG)
Haris h Badrinarayanan (Sage)
...
!-------------------------------1._~~M/~W~B~E~F~i~rm~~---'J -------------------------------
c....
§
Cl)
-"'
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0
Air Quality Study June 2, 2010
8.6 Personnel Qualifications
Tabl e 5 summ a ri zes the c red e nt ia ls and key areas of expert ise fo r t he key E RG tea m me mbe rs.
Short b iog ra phi es fo r each key staff fo ll ow be low, a nd I-page res um es are in Attac hm e nt A.
Table 5. Summary of ERG Team Key Personnel Qualifications
Key Areas of Expertise Related to Gas
I ndustry and A ir Toxics Studies
r:,; >-:, ~> s= $2 > ~
~ flj ~ I= r:,; ., e. e Q r,, ; ~ IJQ
Name, Role Degree(s) e = e Q. "'O e. > "'O = =i .... I:," ~ ~ ~ ril' r= -· = ri Q -· =~ e ,:-:t. ., ., ~ = ~ ;· -· = = -· ~ Q
IJQ = .... IJQ g = = IJQ IJQ .... fl>
M ike Prin g, B.S ., E nvi ro nm enta l • • • Pro ject Manage r Engi nee r ing
C lint Burk lin , B.S ., C he mi cal • • • Sr. Pee r Rev iewe r Eng in eerin g
Jo hn Wil he lm i, B.S ., M .S ., C hemi cal • • Co mmun ications Lead Engi nee rin g
A rn ey Srackangast , B.S., Meteoro logy • • Mo de li ng Lead
Regi Oo mm e n, M .S ., Atmosphe r ic
QA /QC Coo rdin ator Sc iences ; B.S., • • Meteoro logy ; B.A .,
C hemi stry
Scott Finch er, B .S., Meteoro logy • • Mod eli ng Supp o rt
Ray Me rrill , Ph.D., Ph.D ., A na lyt ical
Sr . Ad v isor Sampl ing C hemi stry ; B.S ., •
C hemi stry
Dave Dayton, Mec han ical
Sam plin g Lead Eng in eeri ng •
Dav id Ra num , M .A ., Eng l is h ; A .S., • • • Meas ure me nt s Lead E lectro ni cs
A rt Bedro sian, B .S., Ph ysics • • • • • Sr. A dv iso r Measureme nts
J e nni fe r Parras , B.S ., Env ironme nta l • • • Meas ureme nts S upp ort Engi neeri ng
Ha ri s h Badrin arayanan, M .S ., Environm e nt a l
Meas ureme nt s S upp o rt E ng in eerin g ; M.B.A .; • • • • B.S., C he mi cal
Eng in eerin g
I l
Air Quality Study June 2, 2010
Mike Pring (ERG) is a Senior Env ironmental Engineer specializing in air quality issues,
including emissions inventories , Clean Air Act implementation, air tox ics , and regulatory
compliance. He is the proposed ERG project manager for the City 's NGAQS. As project
manager, he will also have the responsibility of ensuring compliance with the M/WBE
requirements for the contract. Mr. Pring is supporting on-going efforts of the TCEQ to
characterize emissions from upstream oil and gas emissions sources, including drilling engines,
compressor engines, deh y drators, wellheads, oil/gas w ell completions, pneumatic devices,
storage tanks , equipment leaks, and loading racks. Mr. Pring has ten y ears experience supporting
state and local air pollution agencies in reviewing permit applications and writing construction
and operating permits for oil and gas production sources . He provided technical leadership and
overall project management for the preparation of Prevention of Significant Deterioration (PSD),
Title V, and Minor Source Air Quality Permits for large offshore oil and gas exploration and
production platforms, natural gas compressor stations, and natural gas storage facilities . Mr.
Pring has experience with the Toxics Release [nventory (TRI) and the Emergency Planning and
Community Right-to-Know Act of 1986 (EPCRA) reporting requirements.
Clint Burk/in (ERG) is a Principal Engineer and Vice Pres ident with over 35 years of experience
characterizing emiss ions from combustion and fugitive sources, including those within the
natural gas industry. He is a licensed Professional Engineer in North Carolina (see Section 7.0
for a copy of his license.) He will be a Senior Peer reviewer of all work products . Most of his
work has been in the form of technical assistance to national , state, and local air control agencies,
as well as direct technical assistance to electric utilities, energy companies, the Electric Power
Research [nstitute, the American Petroleum Institute and the Gas Research Institute. Mr.
Burklin's experience spans the full range of air pollutants including the criteria pollutants, tox ic
air pollutants, ozone precursors, and greenhouse gases. Currently, he supports projects for the
Western Climate Initiative and the State of New Mexico to develop a GHG reporting protocol
for oil and gas exploration and gas production facilities.
John Wilhelmi (ERG) is a Senior Chemical Engineer and Vice President with 16 years of
e xperience. He will lead the development of the Communications Plan, and provide useful
insights related to health risk for this project. Mr. Wilhelmi has devoted his professional career to
characterizing releases from industrial facilities , evaluating the fate and transport of these
releases, and assessing the human health risks that result from exposures to pollutants in these
releases. Mr. Wilhelmi has researched and reviewed the manufacturing processes, unit
operations, and pollution controls in a wide range of chemical manufacturing and materials
processing industries , including many related to the production and refining of petroleum
products. He has conducted various types of ri s k a s sessment: cancer and non-cancer, acute and
chronic, and direct and indirect. Also, he has prepared and delivered presentations of ranging
technical content at public meetings, scientific conferences, and training courses.
Arney Srackangast (ERG) is a Mid-Level Scientist with 24 years e x perience in managing,
performing, and peer reviewing atmospheric modeling studies in support of federal and state air
quality evaluations. He will lead the dispersion modeling work for this project. Mr. Srackangast
is a recognized expert on the development, application, and use of atmospheric dispersion
models, as well as other air quality topics , including ambient monitoring, emission inventory
development and meteorological data processing. Mr. Srackangast routinely interacts with both
state and federal regulatory agencies to develop thorough modeling methodologies which yield
representative results. Mr. Srackangast has led over 100 air quality analyses in support of various
'1:RG 12
Air Quality Study June 2, 2010
state and federal programs including Prevention of Significant Deterioration (PSD), State
Implementation Plans (SIPs), National Emissions Standards for Hazardous Air Pollutants
(NESHAPs) and state air quality permitting efforts, as well as ambient monitor siting and
exposure analyses (i.e., health risk assessments).
Regi Oommen (ERG) is a Senior Scientist and has over 14 years of air quality and emissions
inventory experience. He will serve as overall QA/QC manager, and will work closely with the
ERG lab on ambient data analysis . Mr. Oommen 's areas of experience include: database
development and management; data collection and analysis ; air quality modeling; emissions
estimation guidance; quality assurance/quality control (QA/QC); planning/meeting support; and
technical writing . For the last several years, Mr. Oommen has been supporting various oil and
natural gas projects for TCEQ and for the Minerals Management Services (MMS) in emissions
estimations and data formatting and management for air quality modeling. For TCEQ, Mr.
Oommen led efforts to estimate 2005 base year criteria air pollutant emissions from selected
exploration activities, such as drilling, degassing, pneumatic pumps, and wellhead completions.
For MMS , Mr. Oommen compiled activity data (e.g., fuel usage , fugitive equipment counts, etc.)
from thousands of offshore oil and natural gas platforms to estimate air emissions. For the past
14 years, he has supported U.S. EPA' s development of the 1990, 1996, 1999, 2002 , and 2005
National Emissions Inventory (NET) and the Urban Air Toxics Monitoring Program . Mr.
Oommen was also the lead data analyst for five Agency for Toxic Substances and Disease
Registry (A TSDR) Exposure Investigations, which summarized air toxics, criteria pollutants, and
harmful sulfur compounds in communities affected by oil and natural gas wells.
Scott Fincher (ERG) is a Staff Scientist with 12 years of air quality experience. He will assist
with the dispersion modeling work for this project. Mr. Fincher has served as a task leader on a
variety of air dispersion modeling projects. He works with environmental agency staff of various
states to ensure use of representative modeling methodologies. Mr. Fincher 's areas of experience
include dispersion modeling for several petrochemical , pulp and paper, electrical generation , and
U .S. military facilities. In addition, he has provided deposition and dispersion modeling in
support of indirect risk assessments. He also has experience with the retrieval , analysis , and
processing of meteorological data when necessary. In recent years, he has assisted various state
agencies with review of dispersion modeling results submitted as part of the permitting process.
Ray Merrill, Ph.D. (ERG) is an internationally recognized environmental chemist with over 33
years of experience managing and performing environmental measurements, methods
development and evaluation, and QA/QC programs. He is experienced in a broad range of
applications chemistry, including routine chemical analysis procedures through complex
instrumental analysis, such as optical remote and mobile monitoring. Dr. Merrill is the QA
Manager for ERG 's laboratory and manages laboratory quality certification under U .S. EPA's
National Environmental Laboratory Accreditation Conference (NELAC). Dr. Merrill is active in
ASTM, NELAC Institute and ISO standard development and consults internationally on
environmental laboratory quality issues , good laboratory practice, and application of ISO 25 to
environmental laboratories.
Dave Dayton (ERG) is a Senior Environmental Engineer with 35 years of experience. He will
be the ambient monitoring task lead. Mr. Dayton has been involved with U.S. EPA 's National
Monitoring Programs since their inception in 1984, with expertise in field sample collection,
sample analysis , and reporting. He developed procedures for analysis of air canister samples to
demonstrate the total nonmethane organic compound content of the canisters (now U.S. EPA
13
Air Quality Study June 2, 2010
Method T0-12). Mr. Dayton designed and fabricated numerous equipment items , which have
become integral to the continued operation of air monitoring networks, such as for U.S. EPA and
ATSDR. He was manager of numerous program s involving sampling and analysis, such as a
program to provide HAPs monitoring at multiple sites compri s ing two separate networks in the
southern Gulf Coast Region of the country. Mr. Dayton has also serv ed as the Project Director on
six exposure investigations for A TSDR involving collection and analysis of samples for VOC ,
carbonyl compounds, and metals, and continuous monitoring for H2S , NH3, S02, inhalable
PM 10, respirable particulate (PM2s ), and meteorology.
David Ranum (Sage) is a Senior Technical Specialist with 25 years of experience in
environmental consulting. Mr. Ranum will lead the point and equipment source emissions
measurements task. His experience includes instrumentation system design, air toxics
monitoring, auditing of environmental systems, water monitoring, fugitive emissions monitoring,
stack testing using CEMs (Continuous Emission Monitors), design and installation of CEM
systems and ambient air monitoring using conventional analyzer systems as well as with FTIR
(Fourier Transform Infrared Spectroscopy) technologies. Mr. Ranum's skills include
instrumentation operation , maintenance , calibration , and repair, environmental sampling,
technical writing, data processing, report writing, project management, and the auditing of
ambient air monitoring systems and LOAR (Leak Detection and Repair) programs. He brings to
the oil and gas industry many years of data collection experience.
Art Bedrosian, QEP (Sage) is a Key Executive Advisor and Client Service Manager with 40
years experience as an air quality professional. He will be an advisor to Sage staff during this
project, and will contribute expertise and guidance to the dispersion modeling task. Mr.
Bedrosian has provided the overall leadership, scheduling, and QA/QC for hundreds of
environmental and engineering projects for almost all types of industries. He has performed
compliance audits for oil and gas production facilities both on and off-shore . He has also
prepared NSR permit applications for gas processing facilities , refineries, chemical plants , and
electric power generating facilities. He has performed atmospheric dispersion modeling for all
types of facilities and for mobile sources as well. [n addition to NSR, his permitting experience
includes federal Title V and PSD permits. He has served for the past 15 years on the Board of
Directors for the Central Texas Clean Air Force to direct ozone monitoring and compliance
efforts. He was selected by Mayor Howard Peak of San Antonio to serve on a small , select blue
ribbon panel tasked with the goal of developing San Antonio 's first air quality policy programs.
Jennifer Parras (Sage) is a Sage Project Manager with more than 12 years of experience in the
oil and gas industry. She will provide technical support for the point and equipment source
sampling. Ms. Parras was an environmental manager for Duke Energy Field Services, Midland ,
TX where she was responsible for environmental compliance of 18 gas plants and 300
compressor stations located in New Mexico and Texas . She managed all compliance for air
quality , water, and waste issues, and was lead auditor for internal corporate environmental
audits. For Alnon, she ensured environmental compliance with all state and federal rule s and for
the implementation and completion of all air compliance issues including permitting,
recordkeeping, monitoring, and reporting. She was also responsible for the LOAR program ,
submitting periodic compliance reports for regulated air emissions, developing compliance of the
applicable units for MACT and NSPS regulations, developing and submitting the annual
emissions inventory and TRI reports, management of Title V compliance, daily transmiss ion of
"=RG 14
Air Quality Study June 2, 2010
reportable emissions to the proper agencies, and environmental guidance on any environmental
issues within the process units.
Harish Badrinarayanan (Sage) is a Technical Specialist (chemical engineer) who has spent
most of the past few years working for Sage on site at upstream and midstream facilities, such as
DCP Midstream , Eagle Rock Energy, and BP North America. He will provide technical support
for the point and equipment source sampling. He has managed and prepared Excess Emissions
and Emission Event reports for natural gas booster stations and gas processing facilities in New
Mexico and Texas. He has managed the preparation of Affirmative Defense (AD) documents in
consultation with field personnel and attorneys. Harish has supported preparation of Permit By
Rule , Standard Permits, and case-by-case NSR permit applications to accurately permit
compressor stations and gas processing plants ; calculated emissions from combustion sources,
blowdown operations, condensate flashing, miscellaneous VOC storage tanks, truck loading,
dehydration units , and fugitive sources. He has prepared emission inventories for natural gas
compressor facilities located in the states of Kansas, New Mexico, and Colorado and a natural
gas liquid facility in Washington; and prepared annual compliance certifications and semi-annual
monitoring reports for facilities in Colorado.
8.7 Laboratories and Accreditations
ERG maintains a NELAP-certified laboratory that conforms fully to all associated quality
requirements (see Section 7.0 for Texas NELAP certification). ERG 's approach for laboratory
analysis is based on more than 26 years experience supporting U.S. EPA's national monitoring
programs. Our laboratory facilities, analytical capacity, and proven approach allows ERG to
achieve a sample completeness rate of 95 percent. We analyze these approximate numbers of
samples annually for various programs:
• Air toxics method T0-15A: 3 ,000 samples
• SNMOC: 1,000 samples
• Metals (Method 10-3.5): 1,000 samples
• Carbonyl compounds (Method T0-1 lA): 3 ,500 samples
• PAHs (Method T0-13A): 1,500 samples
• EPA/ERG Hexavalent Chromium: 1,500 samples
In addition to ERG's in-house laboratory for ambient data analysis, Sage will use the services of
TestAmerica's Austin laboratory , for analysis of source samples. TestAmerica's Austin
laboratory, has provided environmental chemical analyses to government and commercial clients
for over 30 years. TestAmerica has 9 state certifications including NELAP certification in Texas
(see Section 7.0 for Texas NELAP certification).
8.8 Disclosures
For the past three years, ERG has had no current contracts or financial interests with natural gas
producers . Sage 's contracts and revenues with natural gas producers covering the last three years
are listed in the table below. Note that none of these projects were conducted for work on the
Barnett Shale, and the total revenues comprise less than approximately 5% of Sage 's annual 3-
year revenues.
15
Air Quality Study June 2, 2010
,; Sa2e Client 3-Year Revenues Work Product ', 7
American Petroleum Institute $41 ,641 TRI training
Anadarko Petroleum $611 ,677 Auditing program setup
DCP Midstream LP General on -site services ( e .g.,
Title V deviation report,
$385 ,385 LOAR services, etc.)
Eagle Rock Energy Partners, L.P . $297 ,525 EMIS data entry
EGF Energy Partners LLC $23 ,146 TCEQ registrations
El Paso Exploration and Production Environmental comp li ance
$105 ,656 evaluations
Enbridge CAM applicability, emissions
$344 ,227 inventories
Enerplus Resources Corporation $1 ,883 Air compliance support
Enterprise NSPS Kb audit, HRVOC
$71 ,617 audit, standard permitting
Hardin Fuels , Inc . $13 ,645 TCEQ NOV Response
Nob le Energy , Inc. RMP update, permitting
$5 ,811 support
Patriot Operating Company, LLC $14 ,194 Ini tial design PHA
Prism Gas $101 ,997 Pipeline removal
Questar Market Resources Regulatory review (MACT,
$17 ,783 SSM Plans)
Schneider Energy Services Flash emission facto r analys is,
$15 ,407 SPCCp
Stanley Energy, Inc. $4 ,994 Air quality issues support
TEC Inc. $10 ,232 Beaver Creek EIS
Tennessee Gas Pipeline & Affiliates $32 ,480 GHG data collection
U.S . Liquids of LA, LP $11 ,340 SWPPP
VexaPak $13 ,498 SPCC-SWPPP plan
Western Operating Company Semi-annual monitoring
reports , general compliance
$8 ,223 assistance
Whiting Oil and Gas Corporation $170 ,734 Regulatory review /assistance
Williams Production RMT Co. Water facil ities permit, GHG
$17 ,184 emission inventory
C. SCOPE OF SERVICES: METHODOLOGY AND WORK PLAN
The City of Fort Worth is seeking an ind ependent evaluation of emissions generated from
equipment and processes assoc iated with the exploration and production of natural gas . Due to
the rapid increase in the number of natural gas wells drilled and producing in the Barnett Shale
over the last five years, the citizens of the City have become increasingly concerned that they are
being exposed to harmful chemicals emitted from drilling and fracturing equ ipm ent used to drill
wells and bring them into production , and from the natural gas processing and handling
'1:RG 16
Air Quality Study June 2, 2010
equipment used to collect the natural gas and prepare it for market. ERG understands the issues
the City is dealing with , and is well-prepared to answer these fundamental questions:
• What quantity of emissions is coming off of the sites on a volume and mass basis?
• Do the sites comply with applicable regulatory limits?
• What effect do these emissions have on ambient air quality at the fenceline?
• Are the City 's setbacks for wells , tanks , and compressors adequate to protect public health?
In order to answer the first question , the ERG team is fully equipped and experienced to conduct
point source testing to determine the quantity of emissions emitted from drilling and fracturing
operations, from well site equipment (i.e., dehydrators, storage tanks , and leaking pipes and
valves), from natural gas processing equipment (i.e ., compressors, dehydrators, and pipelines),
and from by-product handling (i.e ., Chesapeake 's Brentwood saltwater evaporation and
disposal facility). ERG can quantify emissions of any pollutants of concern , but will focus this
effort on benzene, methane, ethane, VOC , sulfur-containing organics, formaldehyde , NOx, and
PM. Task A, below provides more details on our site-specific sampling methodology.
In order to assess if the City's setback provisions for wells, tanks, and compressors are adequate
to protect public health, ERG will conduct ambient monitoring at locations throughout Fort
Worth , with an emphasis on sensitive receptor locations such as schools , hospitals, and
recreational areas. Ambient monitoring may also be conducted at locations identified as
potential "hot spots" as a result of the point source testing task .
Additionally , ERG will use the site-specific sampling results to conduct dispersion modeling to
determine ambient air quality at the fenceline of potential high emitters. For locations where
multiple sites are in close proximity, the ERG team will include emissions from all nearby sites
in making this determination. Task B , below, describes our approach to dispersion modeling, and
Task C, below, describes our approach to ambient monitoring .
The results of this project will be communicated to the citizens of Fort Worth in language that is
easily understandable , and in a format that is easily accessible and visually informative. ERG
provides outreach services for many of our clients, and Task D, below, provides a description of
how ERG can assist the City in relaying the information gained under this study to its citizenry.
Table 6 provides a tentative schedule of planned dates for project milestones.
Task A: Measure and Analyze Emissions
According to information provided in the pre-qualification meeting on May 20 , 2010 there are
approximately 1,650 natural gas well sites and approximately 600 pads of varying size and
complexity containing natural gas processing and transmission equipment within the municipal
boundaries of the City of Fort Worth , Texas.
Since it is important for public health and safety reasons to identify all sources of emissions
associated with natural gas collection and processing, Sage will perform an initial infrared (IR)
camera survey at each accessible gas well pad and processing facility operating within the City's
~RG 17
Air Quality Study June 2, 2010
Table 6. Project Milestones and Planned Schedule
Planned Completion
Milestone Date 8
Project Kickoff Meetin2 and Work Plan 2nct Week in August
Task A -Measure and Analyze Point Source Emissions
A .1: Identification of well pads and pipelines within the City August 13 , 2010
A.2: Commence IR screening of well pads and pipelines August 16, 2010
A .3: Commence point source testing based on results of IR screening August 30, 2010
A.4: Preparation of point source emissions report December 30, 2010
Task B -Conduct Dispersion Modelin2 b
B.1: Complete facility plot plan review November 26, 2010
8.2: Complete valuation of source locations and release parameters November 26, 2010
B.3: Complete review of receptor placement and classification November 26, 2010
8.4: Meteorological data analysis (if necessary) December 30, 2010
B.5: Model execution and review of results January 28, 2011
B .6: Preparation of dispersion modeling report February 25 , 2011
Task C -Conduct Ambient Samplin2 c
C. l: Network design August 23 , 2010
C .2: Sampling and anal y sis November 24, 2010
C.3: Preparation of ambient sampling report December 30, 2010
Task D -Communication and Outreach Plan
D.1: Communication and outreach plan December 30, 2010
D.2 : Communication and outreach materials February 25, 2011
a Schedule predicated on receipt of Notice to Proceed by August 9, 20 I 0 .
b It is anticipated that the dispersion modeling will not start until the point source testing is completed.
c A ssumes sampling to be conducted August -October with sample analy s is concluding by November 24 .
boundaries. The IR camera provides a quick and effective means of s urveying large areas for
equipment leaks . While the IR camera can not quantify emissions, the extent and density of the
IR image does provide the experienced operator with an indication of the magnitude of the leak.
Leaks identified by the IR camera will be ranked in order of potential magnitude to focus the
sampling program on obtaining actual emission quantities from statistically representative sites.
This two-step approach is important to the statistical validity of the data as well as its spatial
representativeness. Moreover, by prioritizing the sampling process according to the results of the
IR camera surveys, the cost of unnecessary sampling that would occur with a more random
approach can be avoided , providing the City with the best value for its dollar.
Sage will field two IR camera teams in order to complete the survey of natural gas point source
emitters within a reasonable timeframe. In addition , by surveying all possible point source
emission locations, we can more effectively identify the larger emitters and thereby focus the site
specific sampling efforts, the ambient air monitoring, and the dispersion modeling on any
potential "worst case" problem areas that exist. All equipment leaks detected with the lR camera
will be video recorded and documented both with a digital camera and with descriptions
recorded in electronic spreadsheets. All equipment leaks that are accessible to the field crew will
be measured with the TV A l 0008 to determine the leaking concentration.
18
Air Quality Study June 2, 2010
Following the IR camera surveys, emission rates for a selected number of accessible leaks will
be measured directly using the Hi Flow Sampler. Emission rates for leaks found by the camera
on equipment inaccessible to the field crew will be evaluated using average production based
emission factors. Each facility visited by the point source inspection teams will be documented
with photographs as well as by a detailed inventory of major on-site equipment.
Particular attention will be paid to the following point sources as they are frequent sources of
emissions: flares , pipelines, compressors, and condensation tanks. Flare combustion efficiency
can be quickly gauged with the IR camera by viewing the flare plume as it dissipates into the
atmosphere. Quick dissipation is an indication of good combustion efficiency while a long,
cohesive plume indicates just the opposite. Sage will view all flares and a video recording will be
taken of any apparent instances of incomplete flare combustion.
Natural gas pipelines can be the source of very large leaks depending on the age of the pipeline
and the materials of construction. Once the size of the pipeline network has been determined,
Sage, in conjunction with the City of Fort Worth, will determine a representative sample size. A
third IR camera-equipped field team will be assigned to survey the selected pipelines, to
determine leak concentrations with the TV A, to collect canister samples, and to make direct
emission measurements, where possible, with the Hi Flow Sampler. Leaks from compressor
seals and vents are also fairly common. Typically, these leak areas are not readily accessible;
however, every effort will be made when encountering a compressor-related leak to quantify
both its pollutant concentration and emission rate.
Condensation knock out tanks at natural gas facilities are usually equipped with a closed vent
system leading to a control device (flare). The integrity of the closed vent system can quickly be
determined with the IR camera as can high probability leak areas such as poorly sealed thief
hatches, unseated pressure relief valves, and failed conservation vents. Note, that while leaks
from these components are readily detectable with the IR camera, they may not always be
accessible to measurement by the TVA or the Hi Flow Sampler or to canister sample collection.
In order to develop speciation information from point source leaks, a representative number of
canister samples will be collected. The number of canister samples taken will be developed as
details of the testing scheme are worked out. However, this number will most likely be
calculated as a percentage of the number of leaks found for each equipment type. For example, a
10% rate for compressors would mean collection of a canister sample at every l 01h compressor
leak detected with the IR camera. Sage will collect a statistically representative number of
canister samples from each of the following equipment categories:
Wet gas wells
Dry gas wells
Compressor stations
Pipelines
Dehydrators
Tanks
Other major equipment (e.g., process heaters, boilers, etc .)
Automatic control valves
Manual valves
Connectors
Completed canisters will be delivered, along with the appropriate Chain-of-Custody
documentation, to TestAmerica laboratories in Austin , TX. The primary analytical target
compounds will be benzene and carbon disulfide. Additional secondary compounds of interest
are expected to be the same as used by TCEQ for their Barnett Shale monitoring. An emission
rate test will be made with the Hi Flow Sampler in conjunction with each canister sample, in
order to derive compound-specific emission rates for each equipment type sampled.
19
Air Quality Study June 2, 2010
It is important to characterize emissions from natural gas equipment that either has no detectable
emissions, or that is leaking, but at levels below the detection limit of the IR camera. To
accomplish this, direct emission rate measurements with the Hi Flow Sampler will be made on
valves and connectors that 1) have a TV A reading between 100 and 10 ,000 ppm or 2) have only
background readings (i.e. default zeros). The number of valves and connectors to be sampled
will be determined as the scope of work is developed. Based upon Sage 's experience with over
200 fugitive emission-related projects, the following scheme is offered as a starting point.
• Valves 10 ,000 ppm < > 100 ppm - 1 valve/five pads
• Valves O ppm or background -1 valve/IO pads
• Connectors 10 ,000 ppm <> 100 ppm - 1 connector/five pads
• Connectors O ppm or background -1 connector/IO pads
An example of a point source sampling matrix is provided in Table 7.
Table 7. Example Point Source Sample Matrix
,,
IR 0
Point Source Leaks Camera TVA Canister 1 Hi Flow 1
Well Heads • 10% per equip. leak 10% per equip. leak
Compressors • 10% per equip. leak
Flares • Check with the IR camera for combustion efficiency
Pipelines • Sample size to be determined
Dehydrators • 10% per equip. leak
Tanks • 10% per equip. leak
Other Major Equipment • 10% per equip. leak
Automatic Control Valves • 10% per equip. leak 10% per equip. leak
Manual Valves • I 0% per equip. leak 10% per equip. leak
Connectors • 10% per equip. leak 10% per equip. leak
Valves 10 ,000<>lOOppm • l per 5 pads
Valves = 0 ppm • l per 10 pads
Connectors 10 ,000 < > 100 ppm • 1 per 5 pads
Connectors = 0 ppm • 1 per 10 pads
I For 11lustrat1on only . The actual number of canister collect10ns and Ht Flow sampling events will be determined
with the City of Fort Worth during scope of work development.
All testing and sample analysis will be conducted using standard quality control procedures and
within guidelines and practices accepted by federal and state regulators. For example, prior to
use , the [R camera's sensitivity will be validated daily through the following procedures:
1. Following power on and cool down , and after the camera has equilibrated to outside
temperatures, a non-uniformity correction (NUC) will be performed several times.
2 . A flow of propane gas approximately equal to 5 grams/hour will be established and the
furthest distance from which the camera operator can reliably detect the gas flow will be
documented and a video record saved.
3. The gas flow will then be increased to 25 grams/hour and Step 2 repeated.
20
Air Quality Study June 2, 2010
4. The following meteorological conditions will be recorded along with the timestamp and
measured distances: ambient temperature, wind speed ,% relative humidity, barometric
pressure, % cloud cover, and degree of ambient light.
The TVA 1 OOOB will be calibrated daily prior to use with zero air and three upscale certified
span gas concentrations: Low (-500 ppm CH4), Mid (-1000 ppm CH4) and High (-10 ,000 ppm
CH4). An acceptance criterion of± I 0% accuracy will be required for each span calibration point.
Canister quality control procedures will consist of the following :
• Initial and final canister vacuums will be checked and recorded ;
• Canisters will not be filled to less than 10 inches Hg vacuum;
• To avoid dilution of the canister sample by ambient air, the canister sample will be pulled
from as close to the leak interface as possible and will be pulled over a 2 minute period;
• A duplicate sample and field blank will be collected for every ten canister field samples; and
• All required Chain-of-Custody documents will be shipped with each canister sample.
Calibration checks will be performed on the Hi Flow sensor each day prior to use with a 2.5%
Cfti certified compressed gas standard. Once every 30 days (per the manufacturer) the Hi Flow
Sampler will be calibrated with zero air, 2.5% CH4, and 100% CH4 certified compressed gas
standards.
Task B: Conduct Dispersion Modeling
Once testing has been completed , modeling will be conducted to determine the impact emissions
from gas facilities have on air quality at the facility fenceline , and at sensitive receptors in close
proximity to the facility. In addition to modeling conducted at current conditions, ERG will
consider the effect that full build-out of natural gas exploration and production in Fort Worth
will have on future impacts. The following activities will be performed to carry out this analysis:
• Facility plot plan review;
• Evaluation of source locations and release parameters;
• Review of receptor placement and classification;
• Review of model runtime options;
• Meteorological data analysis (if necessary); and
• Model execution.
First, the ERG team will review the plot plans for the facilities to be modeled. From these plot
plans , we will derive appropriate property boundaries and fencelines, and uniquely identify all
emissions sources and downwash structures of interest.
Before modeling can proceed, sources must be correctly classified as either point, volume, or in
some cases, area. Sources must also be located in an appropriate fashion to reflect where on the
property emissions actually occur. Source classification and placement will conform to all TCEQ
and U.S. EPA modeling guidance. A listing of all necessary source parameters input to the model
will be developed , to include emission rates, Universal Transverse Mercator (UTM) coordinates,
base elevation, source height, stack exit velocity and temperature, and source dimensions, as
applicable to each source type. Locations, dimensions, and heights of structures on the property
that could contribute to building downwash will also be clearly presented.
21
Air Quality Study June 2, 2010
ERG will meticulously check the source input parameters developed to ensure that they conform
to all state and federal air quality modeling guidance. If sources with similar parameters are
combined into one source, justification will be provided. Effective plume heights for volume
sources will be calculated appropriately, and volume source dimensions will be divided by a
factor of2 . I 5 according to U.S . EPA guidance. "Pseudo-point" sources (e.g., rain capped or
horizontal stacks) will be modeled w ith an exit velocity ofO.l meters per second. Area sources
will maintain an aspect ratio ofno greater than 10-to-l , and no sources will extend off property .
The receptor grid developed for the facility will consist of both appropriate fenceline receptor
spacing, as determined by the area of the facility , and downwind receptor spacing. ERG expects
that most receptor grid spacing will increase as receptors are located further from the well pad ,
pipeline, or processing facility , but the receptor spacing must still be dense enough to identify
maxima and develop concentration isopleths . Receptors will include terrain heights, and local
land use information will be used to classify receptors as residential , commercial or sensitive.
Acceptable model runtime options have been clearly set forth in TCEQ and the U.S. EPA
guidance. These will be verified for consistency. Notable among the options are that all analyses
should use appropriate dispersion coefficients, as determined by a land-use analysis.
Properly processed meteorological data will be input to the model. TCEQ provides a number of
pre-processed , approved data sets to choose from. Generally, the station closest to the facility
will be used. If not, justification for use of alternate stations will be presented. In the event that
other meteorological data is proposed , at least one complete year of surface observations and
mixing heights must be available, and a description of the methodology and software used to
process the data will be presented .
Having carefully reviewed all modeling input files for completeness, ERG will recommend that
the modeling be executed. As part of the submitted modeling analysis, summaries of model
outputs will be clearly presented. Annual average, max imum hourl y, and other short-term
averaging period concentrations for the pollutants of interest in this study will be reported. Also,
summary plots of the modeled receptor grid , along with pollutant isopleths , will be included.
Task C: Conduct Ambient Sampling
Ambient sampling will be conducted throughout Fort Worth at a variety of locations to obtain a
statistically representative cross-section of ambient exposure to emissions from natural gas
exploration and production sites. ERG will be ready to work with the City at contract initiation
to design the sampling network, including monitor locations and sampling durations. Although
the network will be specific to the scope defined by the City, our approach will consist of three
main activities: network design ; sampling and analysis; and data characterization.
Network Design. The ambient monitoring network will be designed to produce high quality,
representative data. To effectively plan this effort, extensive technical expertise, innovation, and
an in-depth understanding of the intended use of the resulting data are required. Our approach to
the network design for Fort Worth will be as follows:
• Define the problem and/or the goals of the study (e.g., benzene exposure);
• Establish the Data Quality Objectives (DQOs);
• Determine the appropriate measurement methodologies ;
• Survey the study area;
• Identify and address any/all potential limitations to executing the study;
22
Air Quality Study June 2, 2010
• Develop a Quality Assurance Project Plan (QAPP) at the appropriate level of detail ; and
• Implementation , which includes: training and development of operational procedures, pre-
deployment staging, and field deployment.
For the NGAQS, we will use our extensive field and laboratory experience to efficiently set up
the network design. Prior to the initiation of any field work, ERG staff routinely develops
historical and seasonal "windrose" graphs , and prepares a climatological summary of the study
area. These are particularly useful in identifying appropriate locations and objectives for the
monitoring sites, as well as identifying unusual wind patterns that need to be considered in
network design. Monitoring objectives include , but are not limited to source-oriented exposure ,
population exposure, background/remote concentrations, and trends.
We expect to also refine the DQOs to meet the specific objectives of the study. For example ,
typical canister sampling ofVOCs via U.S. EPA Method T0-15 is for a duration of24-hours
(daily). However, during intensive studies, sub-daily measurements can be taken to develop a
diurnal concentration profile that may be more appropriate in understanding the behavior of the
target compounds, such as for BTEX (benzene, toluene, ethylbenzene, and xylenes), and their
potential sources. The City may wish to conduct a combination of I-hour, 3-hour, 6-hour, 8-
hour , and/or 12-hour canister sampling throughout the study to accomplish this . Specifically,
these time period measurements (sub-daily and daily) are useful for:
• Understanding the influence of mobile sources. Samples taken during morning and
afternoon rush hour commutes can be represented effectively using 3-hour samples , and are
useful in understanding contributions from mobile sources. Also, ERG has developed BTEX
signature ratios to help identify concentrations predominantly from mobile sources.
• Understanding non-chronic risk exposure. Samples conducted every hour can be compared
to reference exposure concentrations, such as TCEQs I -hour ESL for benzene or U.S. EPA' s
I-hour and 8-hour Acute Exposure Guideline Levels (AEGL) for mild and moderate effects .
Sampling conducted every 6 hours can be compared to California EPA 's Reference Exposure
Level (REL). 24-hour samples can be compared to U.S. EPA's individual sample
comparison levels and/or ATSDR's acute and intermediate minimal risk levels (MRLs).
• Understanding chronic risk exposure. If the City is interested in developing estimates of
chronic risk , then our sampling schedule would be designed in a manner to ensure enough
concentrations needed to develop an annual average. The annual average would then be used
to calculate chronic risk exposures, such as for cancer and/or noncancer.
Sampling and Analysis. ERG maintains a NELAC-certified laboratory that conforms fully to all
associated quality requirements. As part of our Quality Systems, prior to performing laboratory
analyses, ERG will work with the City to ensure the following:
• The analysis method requested is appropriate for the target analytes;
• The analysis requested will meet the DQOs associated with the corresponding data use; and
• The City understands data turn-around times, and any convoluting elements that may exist.
ERG 's technical approach in performing laboratory analyses is well proven, based on more than
26 years experience supporting U.S. EPA 's National Monitoring Programs, and is widely
~RG 23
Air Quality Study June 2, 2010
accepted by state and federal regulators. The analysis will be conducted under the following six
activities:
• Catalogue of Sample Receipt/Chain-of-Custody forms.
• Review the accompanying field sample collection forms.
• Logging the sample into our Laboratory Information Management System (LIMS) database.
• Sample Preservation and Preparation -ERG preserves and prepares the samples in
accordance with the applicable recognized method , as they are received.
• Analyze samples in accordance with the applicable recognized method.
• Prepare and Distribute Preliminary Data -After analyses have been completed, ERG will
prepare a compiled data report and certificate of analysis for the City .
This LIMS system combines central storage of sample data with multiple access points to the
data throughout the laboratory and associated offices. Information stored in the LIMS covers all
aspects of the life of a sample from receipt to reporting of results. All samples , or sample
components, are tracked by the LIMS . The LIMS system also automatically captures and stores
analytical results directly from the laboratory instruments. This eliminates any potential source
of errors in transcribing raw analytical data.
Data Characterization. There are several data characterization products that the City may want
generated and are generally lumped into two types: statistical and non-statistical. Fundamental
statistical characterization includes calculating the central tendency (e.g., mean , median,
geometric mean , mode , etc.), data distribution (e.g., percentiles, standard deviation , variability,
frequency, confidence intervals, etc.), and correlations of the dataset. A wide range of non-
statistical data visualization products can be constructed using visual plotting software and GlS
information. Non-statistical characterization includes visual plots, pollution roses , and back
trajectories, and may provide more insight than data presented in a tabular form. Integration of
ambient monitoring data and other data sources can yield interesting conclusions. Examples
include:
• [ntegration with meteorological data may include Pearson correlation statistics, construction
of wind and pollution roses, and construction of back trajectories ;
• Integration with emissions data may include: data validation between ambient monitoring
data and emissions inventory , emissions tracing to specific facilities /sources, and toxicity-
weighting of emissions and comparison to ambient monitoring data;
• [ntegration with air regulations data may include: evaluation offederal, state, or local
regulations , pre-and post-implementation; and anticipated reduction in ambient
concentrations due to on-the-books and beyond on-the-books regulations;
• [ntegration with site locations: land use /location setting of monitors, daily traffic patterns ,
nearby population and car registration , topography maps , and climate summaries ; and
• Integration with risk factors may include: individual sample comparison levels , theoretical
cancer risk using Unit Risk Estimate (URE) factors and /or theoretical noncancer risk using
Reference Concentration (RfC) factors , and comparison of measured concentration risk and
NATA-modeled risk
Task D: Develop Communication Plan
The ERG team has extensive experience working with its government clients to communicate
complex technical , scientific , and policy issues to various audiences, including scientific review
boards, environmental regulators , community groups, and the public. We have a proven track
"=RG 24
Air Quality Study June 2, 2010
record of creating effective and engaging outreach and technical materials, which have been
packaged into reports, fact sheets, websites, journal articles, speeches , and presentations. Our
scientists and engineers work closely with technical writers and editors to maximize the impact
of each product by customizing its presentation , content, and language style to the targeted users.
When developing a communications plan , ERG will first coordinate with the City to establish the
community 's information needs and identify the issues of greatest concern (e.g., cancer, non-
cancer effects, e x posure to odors and irritants, etc.). ERG will coordinate with the City to
characterize the intended audience in terms of educational background , languages spoken , access
to computers and the internet, and their most trusted sources of information. ERG can make
recommendations for how best to actively engage interested community members . Three specific
communications issues raised in the RFQ will be addressed as follow s :
Methods used to establish screening levels used by TCEO. Environmental and public health
agencies use different screening levels and guidelines to place environmental measurements into
perspective. Until recently, TCEQ evaluated air monitoring data using a single paradigm:
agency-derived "Effects Screening Levels" (ESLs). ERG has gained extensive experience using
these ES Ls through its ongoing work assisting ATSDR with public health evaluations of air
quality in Corpus Christi and Midlothian , TX. ERG has already drafted text for use in ATSDR
documents to explain these concepts to the public.
More importantly, ERG is also aware of a recent shift in TCEQ methodologies for screening air
pollution levels. Earlier this year, the agency expanded its evaluation approach to use ESLs
primarily for permitting purposes and a new set of screening values-"Air Monitoring
Comparison Values" (or AMCVs)-derived specifically for health-based screening of ambient
air monitoring data. ERG has tracked the development of this new screening paradigm and has
become well-versed on how AMCVs differ from ESLs. A firm knowledge of the difference
between AMCVs and ES Ls is critical for evaluations of ambient air monitoring data in Texas.
Finally, ERG has already researched the methodologies that TCEQ used to derive its AMCVs
and ESLs and is prepared to comment on the various factors that come into play to ensure that
these values are adequately protective (e.g., application of uncertainty factors).
Comparison of different agencies ' health-based screening levels. Earlier in 20 l 0, ERG
performed this exact task . Specifically, we compiled health-based screening levels published by
ATSDR, U.S. EPA, and TCEQ for more than 150 different air pollutants and provided our client
(ATSDR) with detailed information on the similarities and differences between the agency
values. ERG 's risk assessors and environmental health scientists can easil y expand upon this
previous work to include health-based screening values published by other entities, including
international environmental and health organizations.
Consideration of s pecial exposure limits. Through its work for U.S. EPA , ATSDR, and other
agencies, ERG has a proven track record of identifying all screening limits that might be
applicable to a given exposure scenario, including any derived for susceptible populations . For
this project, ERG will first work with the City of Fort Worth to clarify what is meant by "special
exposure limits," as many can potentially apply (e.g., screening values specific to children or the
elderly , screening values based on potential expo s ures via vapor intrusion from groundwater
plumes, soil vapor screening values, sc reening values to protect livestock from ex posures in
oilfield settings). ERG will then access all relevant literature to inform the issues of concern and
communicate the significance of the screening values.
25
5.0 LIST OF SUBCONTRACTORS
Providers shall complete the following information and submit it with the Qualifications Documents to permit the City
of Fort Worth to more fully evaluate the submittal's quality prior to awarding the contract.
Subcontractor's Subcontractor's Subcontractor's Subcontractor's Proposed Tasks
Name Address Telephone No. FAX Number on the Project
4611 Bee Caves Road, lead role for Task A (Measure and
Sage Environmental Suite 100 , Austin , TX 512-327-0288 512-327-4972 l-\nalyze Emissions), and contributions to
Consultants, LP 78746 ~II other tasks for purpo ses of integrating
knowledge of source samp ling and
~nalysis.
6.0 INSURANCE CERTIFICATES
7 .0 PROVIDER'S LICENSES AND CERTIFICATES
Texas Commission on Environmental Quality
NELAP-Recognized Laboratory Accreditation is hereby awarded to
EASTERN RESEARCH GROUP, INC.
601 KEYSTONE PARK DRIVE, SUITE 700
MORRISVILLE, NC 27560-6363
in accordance with Texas Water Code Chapter 5, Subchapter R, Title 30 Texas Administrative
Code Chapter 25, and the· National Environmental Laboratory Accredita.tion Program.
The laboratory's scope of accreditation includes the fields of accreditation that accompany this certificate. Continued
accreditation depends upon successful ongoing participati.on in the program. The Te'.xas Commission on Environmental
Quality urges customers to verify the laboratory's current accreditation status for particuiar methods and analyses.
Certificate Number: T104704426-09-TX-
Effective Date: 07/01/2009
Expiration Date: 06/30/2010 Texas Commission on Environmental Quality
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
Eastern Research Group , Inc. .
601 Keystone Park Drive, Suite 700
Morrisville , NC 27560-6363
Certificate
Issue Date:
Expiration Date:
T1 04704426-09-TX
7/1/2009
6/30/2010
The se fields of accreditation supercede all previous fields . The Texas Comm ission on Env ironmental Qua lity urges customers to verify the
laboratory 's current accreditat ion status for particular methods and analyses .
Matrix: Air and Emissions
Category I Method: EPA T0-15
Analytes: Code AA Analytes: Code AA
1 1 1-T richloroethane 5160 FL 1 1 2 2-Tetrachloroethane 5110 FL
1 1 2-Trich loroethane 5165 FL 1 1-Dichloroethane 4630 FL
1 1-Dichloroethylene 4640 FL 1 2 4-Trichlorobenz ene 5155 FL
1 2-Dichlorobenzene 4610 FL 1 2-Dichloroethane 4635 FL
1 3-D ichlorobenzene 4615 FL 1 4-Dichlorobenzene 4620 FL
2-Butanone (Methyl ethyl ketone MEK) 4410 FL Acetonitrile 4320 FL
Acrylon itrile 4340 FL Benzene 4375 FL
Brornomethane 4950 FL Carbon tetrachloride 4455 FL
Chlorobenzene 4475 FL Ch loroethane 4485 FL
Chloroform 4505 FL Chloromethane 4960 FL
Chloroprene 4525 FL ci s-1 2-Dichloroethylene 4645 FL
cis-1 3-Dichloropropene 4680 FL Ethylbenzene 4765 FL
Methyl isobutyl ketone (Hexone) 4985 FL Methyl methacrylate 4990 FL
Melhyl tert-butyl ether (MTBE) 5000 FL Methylene chloride 4975 FL
Styrene 5100 FL Toluene 5140 FL
trans-1 3-Dichloropropylene 4685 FL Trichloroethene (Trichloroethylene) 5170 FL
Vinyl chloride 5235 FL Xylene (total) 5260 FL
Page 1 of 1
Texas Comrn .is§iQJl \O_n;-,EnyJronn,~q_t~.l:1 QJ.Jaljty
: >:i,/;. •:', .' -:". ·.: .. ,·,:··:· \<---~ . :~ '·<·: ··--.-.. ,' : ' ·_./· .• .' '· ... ; . \".···:· . ·.:: '. ; ; .. '. .. -. ''. . -~
;..-.;,;.'..,<.:;..· :,V.:,-··sr,;,_; •• ~_;; •.. ; .. ,c.., .... ~: .. :.:: ;:l
TestAmerica Laboratories Inc :· ·A:ustin .···. . -..... ,t/ ' .. ' .,
{4 .050 Summit Drive, Suite··A1bcr ·:·"-'·
< /, ->"Austin, TX 78728-7149
-.. ~-: ... ·· .,: .... ,.-
in accordance with Texas Water Code Chapter 5, Subchapter R, Title 30 Texas Administrative Code Chapter 25, and
the National Environmental Laboratory Acc_reditation Program.
The laboratory's scope of accreditation includes the fields of a_ccreditation that accompany this certificate. Continued accreditation depends
upon successful ongoing participation ·in the program. The Texas Commission on Environmental Quality urges customers to verify the
. laboratory's current a~crf;?qjtation stat.us for particular methods and analyses.
•• • . ; ·:->--.', ,·.··.,· .-
Certificate Number:
Effective Date: 3/29/2010
Expiration Date: 6/30/2010
'Executive Director Texas C 1ss1on on
. . .... , .. ,."" .. : •. Si/ Environmental Quality
... ·:J::·.
,•.· .. !.;,.,,.,;.,.; :.·.--.,
---------·
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A 100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Air
Method 40 CFR 50, App . J
Analyte AB Analyte ID Method ID
Particulates <10 um TX 3950 40 CFR 50 App J
Method ASTM 01946
Analyte AB Analyte ID Method ID
Carbon dioxide TX 3755 ASTM 01946-90
Carbon monoxide TX 3780 ASTM 01946-90
Methane TX 4926 ASTM O 1946-90
Nitrogen TX 1843 ASTM O 1946-90
Oxygen TX 3895 ASTM O 1946-90
Method EPA 6010
Analyte AB Analyte ID Method ID
Arsenic TX 1010 10155201
Chromium TX 1040 10155201
Lead TX 1075 10155201
Method EPA T0-12
Analyte AB Analyte ID Method ID
Non-methane hydrocarbons TX 3855 10248201
Method EPA T0-14A
Analyte AB Analyte ID Method ID
1, 1, 1-Trichloroethane TX 5160 10248609
1, 1,2,2-Tetrachloroethane TX 5110 10248609
1, 1,2-Trichloro-1,2,2-trifluoroethane TX 5195 10248609
1 , 1,2-Trichloroethane TX 5165 10248609
1 , 1-Dichloroethane TX 4630 10248609
1 , 1-Dichloroethylene (1, 1-Dichloroethene) TX 4640 10248609
1,2,4-Trichlorobenzene TX 5155 10248609
1,2,4-Trimethylbenzene TX 5210 10248609
1,2-Dibromoethane (EDB, Ethylene dibromide) TX 4585 10248609
1,2-Dichloro-1, 1,2,2-tetrafluoroethane TX 4695 10248609
1,2-Dichlorobenzene TX 4610 10248609
Page 1 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Air
1,2-Dichloroethane TX 4635 10248609
1,2-Dichloropropane TX 4655 10248609
1,3,5-Trimethylbenzene TX 5215 10248609
1,3-Dichlorobenzene TX 4615 10248609
1,4-Dichlorobenzene TX 4620 10248609
Benzene TX 4375 10248609
Benzyl chloride TX 5635 10248609
Bromomethane (Methyl bromide) TX 4950 10248609
Carbon tetrachloride TX 4455 10248609
Chlorobenzene TX 4475 10248609
Chloroethane TX 4485 10248609
Chloroform TX 4505 10248609
Chloromethane (Methyl chloride) TX 4960 10248609
cis-1,2-Dichloroethylene TX 4645 10248609
cis -1,3-Dichloropropylene TX 4680 10248609
Dichlorodifluoromethane TX 4625 10248609
Ethylbenzene TX 4765 10248609
Hexachlorobutadiene TX 4835 10248609
Methylene chloride TX 4975 10248609
Styrene TX 5100 10248609
Tetrachloroethylene (Perchloroethylene) TX 5115 10248609
Toluene TX 5140 10248609
trans-1,2-Dichloroethylene TX 4700 10248609
trans-1,3-Dichloropropylene TX 4685 10248609
Trichloroethane (Trichloroethylene) TX 5170 10248609
Trichlorofluoromethane TX 5175 10248609
Vinyl chloride TX 5235 10248609
Xylene (total) TX 5260 10248609
Method EPA T0-15
Analyte AB Analyte ID Method ID
1, 1, 1-Trichloroethane TX 5160 10248803
Page 2 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for partlcular methods and analyses .
Matrix: Air
1 , 1,2,2-Tetrachloroethane TX 5110 10248803
1 , 1,2-Trichloroethane TX 5165 10248803
1, 1-Dichloroethane TX 4630 10248803
1, 1-Dichloroethylene (1 , 1-Dichloroethene) TX 4640 10248803
1,2,3-Trimethylbenzene TX 5182 10248803
1,2,4-Trichlorobenzene TX 5155 10248803
1,2,4-Trimethylbenzene TX 5210 10248803
1,2-Dibromoethane (EDB, Ethylene dibromide) TX 4585 10248803
1 ,2-Dichlorobenzene TX 4610 10248803
1,2-Dichloroethane TX 4635 10248803
1 ,2-D ichloropropane TX 4655 10248803
1,3,5-Trimethylbenzene TX 5215 10248803
1,3-Butadiene TX 9318 10248803
1,3-Dichlorobenzene TX 4615 10248803
1,4-Dichlorobenzene TX 4620 10248803
1,4-Dioxane (1,4-Diethyleneoxide) TX 4735 10248803
1-Butene TX 4917 10248803
1-Pentene TX 4833 10248803
2 ,2,4-T rimethylpentane TX 5220 10248803
2,2-Dimethylbutane TX 4666 10248803
2,3,4-Trimethylpentane TX 4667 10248803
2 ,3-Dimethylbutane TX 4669 10248803
2,3-Dimethylpentane TX 4671 10248803
2,4-Dimethylpentane TX 4672 10248803
2-Butanone (Methyl ethyl ketone , MEK) TX 4410 10248803
2-Methyl-2-butene TX 10236 10248803
2-Methylheptane TX 4939 10248803
2-Methylhexane TX 10235 10248803
2-Methylpentane (lsohexane) TX 4941 10248803
3-Methyl-1-butene TX 10238 10248803
Page 3 of 41
-----------·-··-·-···--,
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
· 14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Air
3-Methylheptane TX 4532 10248803
3-Methylhexane TX 4533 10248803
3-Methylpentane TX 4534 10248803
4-Methyl-1-pentene TX 10242 10248803
Acetaldehyde TX 4300 10248803
Acetonitrile TX 4320 10248803
Acetylene TX 4323 10248803
Acrylonitrile TX 4340 10248803
Benzene TX 4375 10248803
Benzyl chloride TX 5635 10248803
Bromochloromethane TX 4390 10248803
Bromodichloromethane TX 4395 10248803
Bromoform TX 4400 10248803
Bromomethane (Methyl bromide) TX 4950 10248803
Carbon tetrachloride TX 4455 10248803
Chlorobenzene TX 4475 10248803
Chloroethane TX 4485 10248803
Chloroform TX 4505 10248803
Chloromethane (Methyl chloride) TX 4960 10248803
Chloroprene TX 4525 10248803
cis-1,2-Dichloroethylene TX 4645 10248803
cis-1,3-Dichloropropylene TX 4680 10248803
cis-2-Butene TX 4602 10248803
cis-2-Hexene TX 10244 10248803
cis-2-pentene TX 4603 10248803
Cyclohexane TX 4555 10248803
Cyclopentane TX 4562 10248803
Cyclopentene TX 10247 10248803
Dibromochloromethane TX 4575 10248803
Dichlorodifluoromethane TX 4625 10248803
Page 4 of 41
I
i
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerlca Laboratories, Inc .• Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Air
Dichlorotetrafluoroethane TX 4652 10248803
Ethane TX 4747 10248803
Ethylbenzene TX 4765 10248803
Ethylene TX 4752 10248803
Hexachlorobutadiene TX 4835 10248803
Hexane TX 4850 10248803
lsobutane (2-methylpropane) TX 4942 10248803
lsopentane (2-Methylbutane) TX 4938 10248803
lsoprene (2-Methylbutadiene) TX 4937 10248803
lsopropylbenzene TX 4900 10248803
m+p-xylene TX 5240 10248803
m-Diethylbenzene TX 10252 10248803
Methanol TX 4930 10248803
Methyl isobutyl ketone (Hexane) TX 4985 10248803
Methyl methacrylate TX 4990 10248803
Methyl tert-butyl ether (MTBE) TX 5000 10248803
Methylcyclohexane TX 4965 10248803
Methylcyclopentane TX 4966 10248803
Methylene chloride TX 4975 10248803
m-Ethyltoluene TX 10253 10248803
n-Butane TX 5007 10248803
n-Decane TX 5875 10248803
n-Heptane TX 4825 10248803
n-Nonane TX 5026 10248803
n-Octane TX 5027 10248803
n-Pentane TX 5028 10248803
n-Propylbenzene TX 5090 10248803
n-Undecane TX 10261 10248803
o-Ethyltoluene TX 10254 10248803
a-Xylene TX 5250 10248803
Page 5 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerlca Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5.
6/30/2010
3/29/2010
These fields of accreditati9n supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Air
p-Diethylbenzene TX 10262 10248803
p-Ethyltoluene TX 10255 10248803
Propane TX 5029 10248803
Propylene TX 4836 10248803
Styrene TX 5100 10248803
Tetrachloroethylene (Perchloroethylene) TX 5115 10248803
Toluene TX 5140 10248803
trans-1,2-Dichloroethylene TX 4700 10248803
trans-1,3-Dichloropropylene TX 4685 10248803
trans-2-Butene TX 4607 10248803
trans-2-Hexene TX 10264 10248803
trans-2-pentene TX 4608 10248803
Trichloroethene (Trichloroethylene) TX 5170 10248803
Trichlorofluoromethane TX 5175 10248803
Trichlorotrifluoroethane TX 5185 10248803
Vinyl acetate TX 5225 10248803
Vinyl bromide TX 5230 10248803
Vinyl chloride TX 5235 10248803
Xylene (total) TX 5260 10248803
Page 6 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Method CA HML 939-M
Analyte AB Analyte ID Method ID
Lead, Organic TX 10329 CAHML939-M
Method EPA 1020
Analyte AB Analyte ID Method ID
lgnitability TX 1780 10117007
Method EPA 120.1
Analyte AB Analyte ID Method ID
Conductivity TX 1610 10006403
Method EPA 130 .2
Analyte AB Analyte ID Method ID
Total hardness as CaC03 TX 1755 10007202
Method EPA 150.1
Analyte AB Analyte ID Method ID
pH TX 1900 10008409
Method EPA 160.1
Analyte AB Analyte ID Method ID
Residue-filterable (TDS) TX 1955 10009208
Method EPA 160.2
Analyte AB Analyte ID Method ID
Residue-nonfilterable (TSS) TX 1960 10009606
Method EPA 160.3
Analyte AB Analyte ID Method ID
Residue-total TX 1950 10010001
Method EPA 160.5
Analyte AB Analyte ID Method ID
Residue-settleable TX 1965 10010807
Method EPA 1664
Analyte AB Analyte ID Method ID
n-Hexane Extractable Material (O&G) TX 1803 10127409
Method EPA 200 .7
Analyte AB Analyte ID Method ID
Page 7 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Aluminum TX 1000 10013806
Antimony TX 1005 10013806
Arsenic TX 1010 10013806
Barium TX 1015 10013806
Beryllium TX 1020 10013806
Boron TX 1025 10013806
Cadmium TX 1030 10013806
Calcium TX 1035 10013806
Chromium TX 1040 10013806
Cobalt TX 1050 10013806
Copper TX 1055 10013806
Iron TX 1070 10013806
Lead TX 1075 10013806
Magnesium TX 1085 10013806
Manganese TX 1090 10013806
Molybdenum TX 1100 10013806
Nickel TX 1105 10013806
Phosphorus, total TX 1910 10013806
Potassium TX 1125 10013806
Selenium TX 1140 10013806
Silica-dissolved TX 1995 10013806
Silver TX 1150 10013806
Sodium TX 1155 10013806
Strontium TX 1160 10013806
Thallium TX 1165 10013806
Tin TX 1175 10013806
Titanium TX 1180 10013806
Vanadium TX 1185 10013806
Zinc TX 1190 10013806
Method EPA 200.8
Analyte AB Analyte ID Method ID
Page 8 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Aluminum TX 1000 10014605
Antimony TX 1005 10014605
Arsenic TX 1010 10014605
Barium TX 1015 10014605
Beryllium TX 1020 10014605
Cadmium TX 1030 10014605
Calcium TX 1035 10014605
Chromium TX 1040 10014605
Cobalt TX 1050 10014605
Copper TX 1055 10014605
Iron TX 1070 10014605
Lead TX 1075 10014605
Magnesium TX 1085 10014605
Manganese TX 1090 10014605
Molybdenum TX 1100 10014605
Nickel TX . 1105 10014605
Potassium TX 1125 10014605
Selenium TX 1140 10014605
Silver TX 1150 10014605
Sodium TX 1155 10014605
Strontium TX 1160 10014605
Thallium TX 1165 10014605
Tin TX 1175 10014605
Titanium TX 1180 10014605
Vanadium TX 1185 10014605
Zinc TX 1190 10014605
Method EPA 245 .1
Analyte AB Analyte ID Method ID
Mercury TX 1095 10036609
Method EPA 300 .0
Analyte AB Analyte ID Method ID
Page 9 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A 100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
1104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Bromide TX 1540 10053006
Chloride TX 1575 10053006
Fluoride TX 1730 10053006
Nitrate as N TX 1810 10053006
Nitrite as N TX 1840 10053006
Orthophosphate as P TX 1870 10053006
Sulfate TX 2000 10053006
Method EPA 310 .1
Analyte AB Analyte ID Method ID
Alkalinity as CaC03 TX 1505 10054805
Method EPA 335.1
Analyte AB Analyte ID Method ID
Amenable cyanide TX 1510 10060001
Method EPA 335.3
Analyte AB Analyte ID Method ID
Total cyanide TX 1645 10061004
Method EPA 335.4
Analyte AB Analyte ID Method ID
Total cyan ide TX 1645 10061402
Method EPA 340 .2
Analyte AB Analyte ID Method ID
Fluoride TX 1730 10062201
Method EPA 350.1
Analyte AB Analyte ID Method ID
Ammonia as N TX 1515 10063408
Method EPA 353.2
Analyte AB Analyte ID Method ID
Nitrate-nitrite TX 1820 10067400
Method EPA 365.1
Analyte AB Analyte ID Method ID
Phosphorus, tota l TX 1910 10069804
Page 10 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. • Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217 -10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Method EPA 376 .1
Analyte AB Analyte ID Method ID
Sulfide TX 2005 10074201
Method EPA 410.4
Analyte AB Analyte ID Method ID
Chemical oxygen demand TX 1565 10077200
Method EPA 415 .1
Analyte AB Analyte ID Method ID
Total organic carbon TX 2040 10078407
Method EPA 420 .2
Analyte AB Analyte ID Method ID
Total phenolics TX 1905 10079808
Method EPA 420.4
Analyte AB Analyte ID Method ID
Total phenol ics TX 1905 10080203
Method EPA 6010
Analyte AB Analyte ID Method ID
Aluminum TX 1000 10155609
Antimony TX 1005 10155609
Arsenic TX 1010 10155609
Barium TX 1015 10155609
Beryllium TX 1020 10155609
Boron TX 1025 10155609
Cadmium TX 1030 10155609
Calcium TX 1035 10155609
Chromium TX 1040 10155609
Cobalt TX 1050 10155609
Copper TX 1055 10155609
Iron TX 1070 10155609
Lead TX 1075 10155609
Magnesium TX 1085 10155609
Page 11 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Manganese TX 1090 10155609
Molybdenum TX 1100 10155609
Nickel TX 1105 10155609
Phosphorus, total TX 1910 10155803
Potassium TX 1125 10155609
Selenium TX 1140 10155609
Silica-dissolved TX 1995 10155609
Silver TX 1150 10155609
Sodium TX 1155 10155609
Strontium TX 1160 10155609
Thallium TX 1165 10155609
Tin TX 1175 10155609
Titanium TX 1180 10155609
Vanadium TX 1185 10155609
Zinc TX 1190 10155609
Method EPA 6020
Analyte AB Analyte ID Method ID
Aluminum TX 1000 10156204
Antimony TX 1005 10156204
Arsenic TX 1010 10156204
Barium TX 1015 10156204
Beryllium TX 1020 10156204
Cadmium TX 1030 10156204
Calcium TX 1035 10156204
Chromium TX 1040 10156204
Cobalt TX 1050 10156204
Copper TX 1055 10156204
Iron TX 1070 10156204
Lead TX 1075 10156204
Lithium TX 1080 10156204
Magnesium TX 1085 10156204
Page 12 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. • Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Manganese TX 1090 10156204
Molybdenum TX 1100 10156204 ·
Nickel TX 1105 10156204
Potassium TX 1125 10156204
Selenium TX 1140 10156204
Silver TX 1150 10156204
Sodium TX 1155 10156204
Strontium TX 1160 10156204
Thallium TX 1165 10156204
Tin TX 1175 10156204
Titanium TX 1180 10156204
Vanadium TX 1185 10156204
Zinc TX 1190 10156204
Method EPA 608
Analyte AB Analyte ID Method ID
Aroclor-1016 (PCB-1016) TX 8880 10103603
Aroclor-1221 (PCB-1221) TX 8885 10103603
Aroclor-1232 (PCB-1232) TX 8890 10103603
Aroclor-1242 (PCB-1242) TX 8895 10103603
Aroclor-1248 (PCB-1248) TX 8900 10103603
Aroclor-1254 (PCB-1254) TX 8905 10103603
Aroclor-1260 (PCB-1260) TX 8910 10103603
Method EPA 624
Analyte AB Analyte ID Method ID
1, 1, 1-Trichloroethane TX 5160 10107207
1, 1,2,2-Tetrachloroethane TX 5110 10107207
1, 1,2-Trichloroethane TX 5165 10107207
1, 1-Dichloroethane TX 4630 10107207
1, 1-Dichloroethylene (1 , 1-Dichloroethene) TX 4640 10107207
1,2-Dibromoethane (EDB, Ethylene dibromide) TX 4585 10107207
1,2-Dichlorobenzene TX 4610 10107207
Page 13 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerlca Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
1,2-Dichloroethane TX 4635 10107207
1,2-Dichloropropane TX 4655 10107207
1,3-Dichlorobenzene TX 4615 10107207
1,4-Dichlorobenzene TX 4620 10107207
2-Butanone (Methyl ethyl ketone, MEK) TX 4410 10107207
2-Chloroethyl vinyl ether TX 4500 10107207
Acetone TX 4315 10107207
Acrolein (Propenal) TX 4325 10107207
Acrylonitrile TX 4340 10107207
Benzene TX 4375 10107207
Bromodichloromethane TX 4395 10107207
Bromoform TX 4400 10107207
Bromomethane (Methyl brom ide) TX 4950 10107207
Carbon tetrachloride TX 4455 10107207
Chlorobenzene TX 4475 10107207
Chloroethane TX 4485 10107207
Chloroform TX 4505 10107207
Chloromethane (Methyl chloride) TX 4960 10107207
cis-1 ,2-Dichloroethylene TX 4645 10107207
cis-1 ,3-Dichloropropylene TX 4680 10107207
Dibromochloromethane TX 4575 10107207
Ethylbenzene TX 4765 10107207
m+p-xylene TX 5240 10107207
Methyl tert-butyl ether (MTBE) TX 5000 10107207
Methylene chloride TX 4975 10107207
Naphthalene TX 5005 10107207
a-Xylene TX 5250 10107207
Tetrachloroethylene (Perchloroethylene) TX 5115 10107207
Toluene TX 5140 10107207
trans-1,2-Dichloroethylene TX 4700 10107207
Page 14 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
trans-1,3-Dichloropropylene TX 4685 10107207
Trichloroethane (Trichloroethylene) TX 5170 10107207
Trichlorofluoromethane TX 5175 10107207
Vinyl chloride TX 5235 10107207
Xylene (total) TX 5260 10107207
Method EPA 625
Analyte AB Analyte ID Method ID
1,2,4,5-Tetrachlorobenzene TX 6715 10107401
1,2,4-Trichlorobenzene TX 5155 10107401
1,2-Dichlorobenzene TX 4610 10107401
1,3-Dichlorobenzene TX 4615 10107401
1,4-Dichlorobenzene TX 4620 10107401
2,3,4,6-Tetrachlorophenol TX 6735 10107401
2,4,5-Trichlorophenol TX 6835 10107401
2 ,4,6-Trichlorophenol TX 6840 10107401
2 ,4-Dichlorophenol TX 6000 10107401
2,4-Dimethylphenol TX 6130 10107401
2 ,4-Dinitrop henol TX 6175 10107401
2,4-Dinitrotoluene (2,4-DNT) TX 6185 10107401
2 ,6-Dinitrotoluene (2,6-DNT) TX 6190 10107401
2-Chloronaphthalene TX 5795 10107401
2-Chlorophenol TX 5800 10107401
2-Methyl-4,6-dinitrophenol TX 6360 10107401
2-Methylphenol (o-Cresol) TX 6400 10107401
2-Nitrophenol TX 6490 10107401
3 , 3' -Dichlorobenzidine TX 5945 10107401
4-Bromophenyl phenyl ether TX 5660 10107401
4-Chloro-3-methylphenol TX 5700 10107401
4-Chlorophenyl phenylether TX 5825 10107401
4-Methylphenol (p-Cresol) TX 6410 10107401
4-Nitrophenol TX 6500 10107401
Page 15 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Acenaphthene TX 5500 10107401
Acenaphthylene TX 5505 10107401
Anthracene TX 5555 10107401
Benzidine TX 5595 10107401
Benzo(a)anthracene TX 5575 10107401
Benzo(a)pyrene TX 5580 10107401
Benzo(b )fluoranthene TX 5585 10107401
Benzo(g ,h, i)perylene TX 5590 10107401
Benzo(k)fluoranthene TX 5600 10107401
bis(2-Chloroethoxy)methane TX 5760 10107401
bis(2-Chloroethyl) ether TX 5765 10107401
b is(2-Chloroisopropyl) ether TX 5780 10107401
bis(2-Ethylhexyl) phthalate (DEHP) TX 6255 10107401
Butyl benzyl phthalate TX 5670 10107401
Chrysene TX 5855 10107401
Dibenz(a ,h) anthracene TX 5895 10107401
Diethyl phthalate TX 6070 10107401
Dimethyl phthalate TX 6135 10107401
Di-n-butyl phthalate TX 5925 10107401
Di-n-octyl phthalate TX 6200 10107401
Fluoranthene TX 6265 10107401
Fluorene TX 6270 10107401
Hexachlorobenzene TX 6275 10107401
Hexachlorobutadiene TX 4835 10107401
Hexachlorocyclopentadiene TX 6285 10107401
Hexachloroethane TX 4840 10107401
lndeno(1,2,3-cd) pyrene TX 6315 10107401
lsophorone TX 6320 10107401
Naphthalene TX 5005 10107401
Nitrobenzene TX 5015 10107401
Page 16 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
1104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
n-Nitrosodiethylamine TX 6525 10107401
n-Nitrosodimethylamine TX 6530 10107401
n-Nitroso-di-n-butylamine TX 5025 10107401
n-Nitrosodi-n-propylamine TX 6545 10107401
n-Nitrosodiphenylamine TX 6535 10107401
Pentachlorobenzene TX 6590 10107401
Pentachlorophenol TX 6605 10107401
Phenanthrene TX 6615 10107401
Phenol TX 6625 10107401
Pyrene TX 6665 10107401
Pyridine TX 5095 10107401
Method EPA 7196
Analyte AB Analyte ID Method ID
Chromium VI TX 1045 10162400
Method EPA 7470
Analyte AB Analyte ID Method ID
Mercury TX 1095 10165807
Method EPA 8015
Analyte AB Analyte ID Method ID
Diesel range organ ics (DRO) TX 9369 10173601
Ethanol TX 4750 10173601
Ethylene glycol TX 4785 10173601
Gasoline range organics (GRO) TX 9408 10173601
lsobutyl alcohol (2-Methyl-1-propanol) TX 4875 10173601
lsopropanol TX 4885 10173601
Methanol TX 4930 10173601
n-Butyl alcohol TX 4425 10173601
n-Propanol TX 5055 10173601
Propylene Glycol TX 6657 10173601
tert-Butyl alcohol TX 4420 10173601
Page 17 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Method EPA 8082
Analyte · AB Analyte ID Method ID
Aroclor-1016 (PCB-1016) TX 8880 10179007
Aroclor-1221 (PCB-1221) TX 8885 10179007
Aroclor-1232 (PCB-1232) TX 8890 10179007
Aroclor-1242 (PCB-1242) TX 8895 10179007
Aroclor-1248 (PCB-1248) TX 8900 10179007
Aroclor-1254 (PCB-1254) TX 8905 10179007
Aroclor-1260 (PCB-1260) TX 8910 10179007
Method EPA 8260
Analyte AB Analyte ID Method ID
1, 1, 1 ,2-Tetrachloroethane TX 5105 10184802
1, 1, 1-Trichloroethane TX 5160 10184802
1 , 1,2,2-Tetrachloroethane TX 5110 10184802
1 , 1,2-Trichloroethane TX 5165 10184802
1, 1-Dichloroethane TX 4630 10184802
1, 1-Dichloroethylene (1, 1-Dichloroethene) TX 4640 10184802
1 , 1-Dichloropropene TX 4670 10184802
1 ,2,3-Trichlorobenzene TX 5150 10184802
1,2, 3-T rich loropropane TX 5180 10184802
1 ,2,4-Trichlorobenzene TX 5155 10184802
1 ,2,4-Trimethylbenzene TX 5210 10184802
1,2-Dibromo-3-chloropropane (DBCP) TX 4570 10184404
1,2-Dibromoethane (EDB, Ethylene dibromide) TX 4585 10184802
1,2-Dichlorobenzene TX 4610 10184802
1,2-Dichloroethane TX 4635 10184802
1,2-Dichloropropane TX 4655 10184802
1,3,5-Trimethylbenzene TX 5215 10184802
1,3-Dichlorobenzene TX 4615 10184802
1,3-Dichloropropane TX 4660 10184802
1,4-Dichlorobenzene TX 4620 10184802
Page 1Bof41
Texas Commission Qn
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
1104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
1,4-Dioxane (1,4-Diethyleneoxide) TX 4735 10184802
1-Chlorohexane TX 4510 10184802
2,2-Dichloropropane TX 4665 10184802
2-Butanone (Methyl ethyl ketone , MEK) TX 4410 10184802
2-Chloroethyl vinyl ether TX 4500 10184802
2-Chlorotoluene TX 4535 10184802
2-Hexanone TX 4860 10184802
2-N itropropane TX 5020 10184802
4-Chlorotoluene TX 4540 10184802
4-lsopropyltoluene TX 4915 10184802
4-Methyl-2-pentanone (MIBK) TX 4995 10184802
Acetone TX 4315 10184802
Acetonitrile TX 4320 10184802
Acrolein (Propenal) TX 4325 10184802
Acryloniti"ile TX 4340 10184802
Allyl chloride (3 -Chloropropene) TX 4355 10184802
Benzene TX 4375 10184802
Benzyl chloride TX 5635 10184802
Bromobenzene TX 4385 10184802
Bromochloromethane TX 4390 10184802
Bromodichloromethane TX 4395 10184802
Bromoform TX 4400 10184802
Bromomethane (Methyl bromide) TX 4950 10184802
Carbon disulfide TX 4450 10184802
Carbon tetrachloride TX 4455 10184802
Chlorobenzene TX 4475 10184802
Chloroethane TX 4485 10184802
Chloroform TX 4505 10184802
Chloromethane (Methyl chloride) TX 4960 10184802
Chloroprene TX 4525 10184802
Page 19 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
cis-1 ,2-Dichloroethylene TX 4645 10184802
cis-1 ,3-Dichloropropylene TX 4680 10184802
Dibromochloromethane TX 4575 10184802
Dibromomethane TX 4595 10184802
Dichlorodifluoromethane TX 4625 10184802
Diethyl ether TX 4725 10184802
Epichlorohydrin (1-Chloro-2,3-epoxypropane) TX 4745 10184802
Ethanol TX 4750 10184802
Ethyl methacrylate TX 4810 10184802
Ethyl benzene TX 4765 10184802
Ethylene oxide TX 4795 10184802
Hexachlorobutadiene TX 4835 10184802
lodomethane (Methyl iodide) TX 4870 10184802
lsobutyl alcohol (2-Methyl-1-propanol) TX 4875 10184802
lsopropyl ether TX 4905 10184802
lsopropylbenzene TX 4900 10184802
m+p-xylene TX 5240 10184802
Methacrylonitrile TX 4925 10184802
Methyl acetate TX 4940 10184802
Methyl methacrylate TX 4990 10184802
Methyl tert-butyl ether (MTBE) TX 5000 10184802
Methylene chloride TX 4975 10184802
Naphthalene TX 5005 10184802
n-Butyl alcohol TX 4425 10184802
n-Butylbenzene TX 4435 10184802 .
n-Propylbenzene TX 5090 10184802
a-Xylene TX 5250 10184802
Pentachloroethane TX 5035 10184802
Propionitrile (Ethyl cyanide) TX 5080 10184802
sec-Butylbenzene TX 4440 10184802
Page 20 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Styrene TX 5100 10184802
tert-Butyl alcohol TX 4420 10184802
tert-Butylbenzene TX 4445 10184802
Tetrachloroethylene (Perchloroethylene) TX 5115 10184802
Toluene TX 5140 10184802
trans-1,2-Dichloroethylene TX 4700 10184802
trans-1,3-Dichloropropylene TX 4685 10184802
trans-1,4-Dichloro-2-butene TX 4605 10184802
Trichloroethene (Trichloroethylene) TX 5170 10184802
Trichlorofluoromethane TX 5175 10184802
Trichlorotrifluoroethane TX 5185 10184802
Vinyl acetate TX 5225 10184802
Vinyl chloride TX 5235 10184802
Xylene (total) TX 5260 10184802
Method EPA 8270
Analyte AB Analyte ID Method ID
1,2,4,5-Tetrachlorobenzene TX 6715 10185805
1,2,4-Trichlorobenzene TX 5155 10185805
1,2-Dichlorobenzene TX 4610 10185805
1,2-Diphenylhydrazine TX 6220 10185805
1,3,5-Trinitrobenzene (1,3,5-TNB) TX 6885 10185805
1,3-Dichlorobenzene TX 4615 10185805
1,3-Dinitrobenzene (1,3-DNB) TX 6160 10185805
1,4-Dichlorobenzene TX 4620 10185805
1,4-Dinitrobenzene TX 6165 10185203
1,4-Naphthoquinone TX 6420 10185805
1,4-Phenylenediamine TX 6630 10185601
1-Naphthylamine TX 6425 10185805
2 ,3;4,6-Tetrachlorophenol TX 6735 10185805
2 ,4 , 5-Trichlorophenol TX 6835 10185805
2,4,6-Trichlorophenol TX 6840 10185805
Page 21 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
2,4-Dichlorophenol TX 6000 10185805
2,4-Dimethylphenol TX 6130 10185805
2,4-Dinitrophenol TX 6175 10185805
2,4-Dinitrotoluene (2,4-DNT) TX 6185 10185805
2,6-Dichlorophenol TX 6005 10185805
2,6-Dinitrotoluene (2,6-DNT) TX 6190 10185805
2-Acetylaminofluorene TX 5515 10185805
2-Chloronaphthalene TX 5795 10185805
2-Chlorophenol TX 5800 10185805
2-Methyl-4 ,6-dinitrophenol TX 6360 10185805
2-Methylnaphthalene TX 6385 10185805
2-Methylphenol (o -Cresol) TX 6400 10185805
2-Naphthylamine TX 6430 10185805
2-Nitroaniline TX 6460 10185805
2-Nitrophenol TX 6490 10185805
2-Picoline (2-Methylpyridine) TX 5050 10185805
3,3'-Dichlorobenzidine TX 5945 10185805
3,3'-Dimethylbenzidine TX 6120 10185805
3-Methylcholanthrene TX 6355 10185805
3-Nitroaniline TX 6465 10185805
4 ,4' -Methylenebis(2-chloroaniline) TX 6365 10185805
4-Aminob iphenyl TX 5540 10185805
4-Bromophenyl phenyl ether TX 5660 10185805
4-Chloro-3-methylphenol TX 5700 10185805
4-Chloroaniline TX 5745 10185805
4-Chlorophenyl phenylether TX 5825 10185805
4-Dimethyl aminoazobenzene TX 6105 10186002
4-Methylphenol (p-Cresol) TX 6410 10185805
4-Nitroaniline TX 6470 10185805
4-N itrophenol TX 6500 10185805
Page 22 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
5-Nitro-o-toluidine TX 6570 10185805
7 , 12-Dimethylbenz(a) anthracene TX 6115 10185805
a-a-Dimethylphenethylamine TX 6125 10185805
Acenaphthene TX 5500 10185805
Acenaphthylene TX 5505 10185805
Acetophenone TX 5510 10185805
Aniline TX 5545 10185805
Anthracene TX 5555 10185805
Aramite TX 5560 10186002
Benzi dine TX 5595 10185805
Benzo( a )a nth racene TX 5575 10185805
Benzo( a )pyrene TX 5580 10185805
Benzo(b )fluoranthene TX 5585 10185805
Benzo(g, h, i)perylene TX 5590 10185805
Benzo(k)fluoranthene TX 5600 10185805
Benzoic acid TX 5610 10185805
Benzyl alcohol TX 5630 10185805
Biphenyl TX 5640 10185601
bis(2-Chloroethoxy)methane TX 5760 10185805
bis(2-Chloroethyl) ether TX 5765 10185805
bis(2-Chloroisopropyl) ether TX 5780 10185805
bis(2-Ethylhexyl) phthalate (DEHP) TX 6255 10185805
Butyl benzyl phthalate TX 5670 10185805
Carbazole TX 5680 10185805
Chlorobenzilate TX 7260 10185805
Chrysene TX 5855 10185805
Diallate TX 7405 10185805
Dibenz(a,h) anthracene TX 5895 10185805
Dibenzo(a,e) pyrene TX 5890 10185805
Dibenzofuran TX 5905 10185805
Page 23 of41
I
1
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Diethyl phthalate TX 6070 10185805
Dimethoate TX 7475 10185601
Dimethyl phthalate TX 6135 10185805
Di-n-butyl phthalate TX 5925 10185805
Di -n-octyl phthalate TX 6200 10185805
Dinoseb (2-sec-butyl-4,6-dinitrophenol, DNBP) TX 8620 10185805
Disulfoton TX 8625 10185203
Ethyl methanesulfonate TX 6260 10185805
Famphur TX 7580 10186002
Fluoranthene TX 6265 10185805
Fluorene TX 6270 10185805
Hexachlorobenzene TX 6275 10185805
Hexachlorobutadiene TX 4835 10185805
Hexachlorocyclopentadiene TX 6285 10185805
Hexachloroethane TX 4840 10185805
Hexachloropropene TX 6295 10185805
lndeno(1,2,3-cd) pyrene TX 6315 10185805
lsodrin TX 7725 10185805
lsophorone TX 6320 10185805
lsosafrole TX 6325 10185805
Kepone TX 7740 10185805
Methapyrilene TX 6345 10185805
Methyl methanesulfonate TX 6375 10185805
Naphthalene TX 5005 10185805
Nitrobenzene TX 5015 10185805
Nitroquinoline-1-oxide TX 6515 10185805
n-Nitrosodiethylamine TX 6525 10185805
n-Nitrosodimethylamine TX 6530 10185805
n-Nitroso-di-n-butylamine TX 5025 10185805
n-Nitrosodi-n-propylamine TX 6545 10185805
Page 24 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
1104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
n-Nitrosodiphenylamine TX 6535 10185805
n-Nitrosomethylethylamine TX 6550 10185805
n-Nitrosomorpholine TX 6555 10185805
n-Nitrosopiperidine TX 6560 10185805
n-Nitrosopyrrolidine TX 6565 10185805
o,o,o-Triethyl phosphorothioate TX 8290 10185805
o-Toluidine TX 5145 10185805
Parathion, ethyl TX 7955 10185601
Parathion , methyl (Methyl parathion) TX 7825 10185203
Pentachlorobenzene TX 6590 10185805
Pentachloronitrobenzene TX 6600 10185805
Pentach lorophenol TX 6605 10185805
Phenacetin TX 6610 10185805
Phenanthrene TX 6615 10185805
Phenol TX 6625 10185805
Phorate TX 7985 10185203
Pronamide (Kerb) TX 6650 10185805
Pyrene TX 6665 10185805
Pyridine TX 5095 10185805
Safrole TX 6685 10185805
Sulfotepp TX 8155 10186002
Thionazin (Zinophos) TX 8235 10185805
Method EPA 9012
Analyte AB Analyte ID Method ID
Amenable cyanide TX 1510 10193405
Total Cyanide TX 1635 10193405
Method EPA 9034
Analyte AB Analyte ID Method ID
Total sulfides TX 2010 10196006
Method EPA 9040
Analyte AB Analyte ID Method ID
Page 25 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica. Laboratories, Inc. • Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses .
Matrix: Non Potable Water
pH TX 1900 10197203
Method EPA 9050
Analyte AB Analyte ID Method ID
Conductivity TX 1610 10198808
Method EPA 9056
Analyte AB Analyte ID Method ID
Bromide TX 1540 10199209
Chloride TX 1575 10199209
Fluoride TX 1730 10199209
Nitrate as N TX 1810 10199209
Nitrite as N TX 1840 10199209
Orthophosphate as P TX 1870 10199209
Sulfate TX 2000 10199209
Method EPA 9060
Analyte AB Analyte ID Method ID
Total organic carbon TX 2040 10200201
Method EPA 9066
Analyte AB Analyte ID Method ID
Total phenolics TX 1905 10200609
Method Iowa OA-1 ; GRO
Analyte AB Analyte ID Method ID
Volatile Petroleum Hydrocarbons TX 10330 90016403
Method Iowa OA-2 ; ORO
Analyte AB Analyte ID Method ID
Extractable Petroleum Hydrocarbons TX 10331 90016607
Method QuickChem10-204-00-1-X
Analyte AB Analyte ID Method ID
Total Cyanide TX 1635 60030800
Method RSK 175
Analyte AB Analyte ID Method ID
Carbon dioxide TX 3755 RSK 175
Page 26 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerlca Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Ethane TX 4747 RSK 175
Ethylene TX 4752 RSK 175
lsobutane (2-methylpropane) TX 4942 RSK 175
Methane TX 4926 RSK 175
n-Butane TX 5007 RSK 175
Propane · TX 5029 RSK 175
Method SM 2320 B
Analyte AB Analyte ID Method ID
Alkalinity as CaC03 TX 1505 20003003
Method SM 2340 B
Analyte AB Analyte ID Method ID
Total hardness as CaC03 TX 1755 20003401
Method SM 2340 C
Analyte AB Analyte ID Method ID
Total hardness as CaC03 TX 1755 20003605
Method SM 2510 B
Analyte AB Analyte ID Method ID
Conductivity TX 1610 20003809
Method SM 2540 B
Analyte AB Analyte ID Method ID
Residue-total TX 1950 20004608
Method SM 2540 C
Analyte AB Analyte ID Method ID
Residue-filterable (TDS) TX 1955 20004404
Method SM 2540 D
Analyte AB Analyte ID Method ID
Residue-nonfilterable (TSS) TX 1960 20004802
Method SM 2540 F
Analyte AB Analyte ID Method ID
Residue-settleable TX 1965 20005009
Method SM 3500 Cr D
Analyte AB Analyte ID Method ID
Page 27 of 41
"
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Chromium VI TX 1045 20009001
Method SM 4500 CN E
Analyte AB Analyte ID Method ID
Total Cyanide TX 1635 20021209
Method SM 4500 CN G
Analyte AB Analyte ID Method ID
Amenable cyanide TX 1510 20021607
Method SM 4500 F-C
Analyte AB Analyte ID Method ID
Fluoride TX 1730 20012800
Method SM 4500 H+ 8
Analyte AB Analyte ID Method ID
pH TX 1900 20016404
Method SM 4500 N03 F
Analyte AB Analyte ID Method ID
Nitrate-nitrite TX 1820 20024402
Method SM 4500 P F
Analyte AB Analyte ID Method ID
Phosphorus, total TX 1910 20026000
Method SM 4500 S2-F
Analyte AB Analyte ID Method ID
Sulfide TX 2005 20126209
Method SM 5220 D
Analyte AB Analyte ID Method ID
Chemical oxygen demand TX 1565 20027809
Method SM 5310 C
Analyte AB Analyte ID Method ID
Total organic carbon TX 2040 20028200
Method TCEQ 1005
Analyte AB Analyte ID Method ID
Total Petroleum Hydrocarbons (TPH) TX 2050 90019208
Page 28 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Non Potable Water
Method Tennessee EPH
Analyte AB Analyte ID Method ID
Extractable Petroleum Hydrocarbons TX 10331 Tennessee EPH
Method Tennessee GRO
Analyte AB Analyte ID Method ID
Gasoline range organics (GRO) TX 9408 Tennessee GRO
Page 29 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
Method CA HML 939-M
Analyte AB Analyte ID Method ID
Lead, Organic TX 10329 CA HML939-M
Method EPA 1020
Analyte AB Analyte ID Method ID
lgnitability TX 1780 10117007
Method EPA 1311
Analyte AB Analyte ID Method ID
TCLP TX 849 10118806
Method EPA 1312
Analyte AB Analyte ID Method ID
SPLP TX 850 10119003
Method EPA 350.1
Analyte AB Analyte ID Method ID
Ammonia as N TX 1515 10063408
Method EPA 6010
Analyte AB Analyte ID Method ID
Aluminum TX 1000 10155609
Antimony TX 1005 10155609
Arsenic TX 1010 10155609
Barium TX 1015 10155609
Beryllium TX 1020 10155609
Boron TX 1025 10155609
Cadmium TX 1030 10155609
Calcium TX 1035 10155609
Chromium TX 1040 10155609
Cobalt TX 1050 10155609
Copper TX 1055 10155609
Iron TX 1070 10155609
Lead TX 1075 10155609
Magnesium TX 1085 10155609
Page 30 of41
~
I
---------
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
Manganese TX 1090 10155609
Molybdenum TX 1100 10155609
Nickel TX 1105 10155609
Phosphorus, total TX 1910 10155609
Potassium TX 1125 10155609
Selenium TX 1140 10155609
Silica as Si02 TX 1990 10155609
Silver TX 1150 10155609
Sodium TX 1155 10155609
Strontium TX 1160 10155609
Thallium TX 1165 10155609
Tin TX 1175 10155609
Titanium TX 1180 10155609
Vanadium TX 1185 10155609
Zinc TX 1190 10155609
Method EPA 6020
Analyte AB Analyte ID Method ID
Aluminum TX 1000 10156204
Antimony TX 1005 10156204
Arsenic TX 1010 10156204
Barium TX 1015 10156204
Beryllium TX 1020 10156204
Cadmium TX 1030 10156204
Calcium TX 1035 10156204
Chromium TX 1040 10156204
Cobalt TX 1050 10156204
Copper TX 1055 10156204
Iron TX 1070 10156204
Lead TX 1075 10156204
Lithium TX 1080 10156204
Magnesium TX 1085 10156204
Page 31 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. • Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
1104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
. Manganese TX 1090 10156204
Molybdenum TX 1100 10156204
Nickel TX 1105 10156204
Potassium TX 1125 10156204
Selen ium TX 1140 10156204
Silver TX 1150 10156204
Sodium TX 1155 10156204
Strontium TX 1160 10156204
Thallium TX 1165 10156204
T in TX 1175 10156204
Titanium TX 1180 10156204
Vanadium TX 1185 10156204
Zinc TX 1190 10156204
Method EPA 7196
Analyte AB Analyte ID Method ID
Chromium VI TX 1045 10162400
Method EPA 7471
Analyte AB Analyte ID Method ID
Mercury TX 1095 10166208
Method EPA 8015
Analyte AB Analyte ID Method ID
2-Propanol (lsopropyl alcohol) TX 4895 10173601
Diesel range organics (DRO) TX 9369 10173601
Ethanol TX 4750 10173601
Ethylene glycol TX 4785 10173601
Gasoline range organics (GRO) TX 9408 10173601
lsobutyl alcohol (2-Methyl-1-propanol) TX 4875 10173601
Methanol TX . 4930 10173601
n-Butyl alcobol TX 4425 10173601
n-Propanol TX 5055 10173601
Propylene Glycol TX 6657 10173601
Page 32 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A 100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields . The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
tert-Butyl alcohol TX 4420 10173601
Method EPA 8082
Analyte AB Analyte ID Method ID
Aroclor-1016 (PCB-1016) TX 8880 10179007
Aroclor-1221 (PCB-1221) TX 8885 10179007
Aroclor-1232 (PCB-1232) TX 8890 10179007
Aroclor-1242 (PCB-1242) TX 8895 10179007
Aroclor-1248 (PCB-1248) TX 8900 10179007
Aroclor-1254 (PCB-1254) TX 8905 10179007
Aroclor-1260 (PCB-1260) TX 8910 10179007
Method EPA 8260
Analyte AB Analyte ID Method ID
1, 1, 1,2-Tetrachloroethane TX 5105 10184802
1, 1, 1-Trichloroethane TX 5160 10184802
1, 1,2,2-Tetrachloroethane TX 5110 10184802
1, 1,2-Trichloroethane TX 5165 10184802
1, 1-Dichloroethane TX 4630 10184802
1, 1-Dichloroethylene (1, 1-Dichloroethene) TX 4640 10184802
1, 1-Dichloropropene TX 4670 10184802
1,2,3-Trichlorobenzene TX 5150 10184802
1,2,3-Trichloropropane TX 5180 10184802
1,2,4-Trichlorobenzene TX 5155 10184802
1 ,2,4-Trimethylbenzene TX 5210 10184802
1,2-Dibromo-3-chloropropane (DBCP) TX 4570 10184802
1,2-Dibromoethane (EDB, Ethylene dibromide) TX 4585 10184802
1,2-Dichlorobenzene TX 4610 10184802
1,2-Dichloroethane TX 4635 10184802
1,2-Dichloropropane TX 4655 10184802
1,3,5-Trimethylbenzene TX 5215 10184802
1,3-Dichlorobenzene TX 4615 10184802
1,3-Dichloropropane TX 4660 10184802
Page 33 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
1,4-Dichlorobenzene TX 4620 10184802
1,4-Dioxane (1,4-Diethyleneoxide) TX 4735 10184802
1-Chlorohexane TX 4510 10184802
2,2-Dichloropropane TX 4665 10184802
2-Butanone (Methyl ethyl ketone, MEK) TX 4410 10184802
2-Chloroethyl vinyl ether TX 4500 10184802
2-Chlorotoluene TX 4535 10184802
2-Hexanone TX 4860 10184802
2-Nitropropane TX 5020 10184802
4-Chlorotoluene TX 4540 10184802
4-lsopropyltoluene TX 4915 10184802
4-Methyl-2-pentanone (MIBK) TX 4995 10184802
Acetone TX 4315 10184802
Acetonitrile TX 4320 10184802
Acrole in (Propenal) TX 4325 10184802
Acrylonitrile TX 4340 10184802
Allyl chloride (3-Chloropropene) TX 4355 10184802
Benzene TX 4375 10184802
Benzyl chloride TX 5635 10184802
Bromobenzene TX 4385 10184802
Bromochloromethane TX 4390 10184802
Bromodichloromethane TX 4395 10184802
Bromoform TX 4400 10184802
Bromomethane (Methyl bromide) TX 4950 10184802
Carbon disulfide TX 4450 10184802
Carbon tetrachloride TX 4455 10184802
Chlorobenzene TX 4475 10184802
Chloroethane TX 4485 10184802
Chloroform TX 4505 10184802
Chloromethane (Methyl chloride) TX 4960 10184802
Page 34 of 41
I
"
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
Chloroprene TX 4525 10184802
cis-1 ,2-Dichloroethylene TX 4645 10184802
cis-1 ,3-Dichloropropylene TX 4680 10184802
Dibromochloromethane TX 4575 10184802
Dibromomethane TX 4595 10184802
Dichlorodifluoromethane TX 4625 10184802
Diethyl ether TX 4725 10184802
Epichlorohydrin (1-Chloro-2 ,3-epoxypropane) TX 4745 10184802
Ethanol TX 4750 10184802
Ethyl acetate TX 4755 10184802
Ethyl methacrylate TX 4810 10184802
Ethylbenzene TX 4765 10184802
Ethylene oxide TX 4795 10184802
Hexachlorobutadiene TX 4835 10184802
lodomethane (Methyl iodide) TX 4870 10184802
lsobutyl alcohol (2-Methyl-1-propanol) TX 4875 10184802
lsopropylbenzene TX 4900 10184802
m+p-xylene TX 5240 10184802
Methacrylonitrile TX 4925 10184802
Methyl methacrylate TX 4990 10184802
Methyl tert-butyl ether (MTBE) TX 5000 10184802
Methylene chloride TX 4975 10184802
Naphthalene TX 5005 10184802
n-Butyl alcohol TX 4425 10184802
n-Butylbenzene TX 4435 10184802
n-Propylbenzene TX 5090 10184802
o-Xylene TX 5250 10184802
Pentach loroethane TX 5035 10184802
Propionitrile (Ethyl cyanide) TX 5080 10184802
sec-Butylbenzene TX 4440 10184802
Page 35 of 41
-,
' i
I
I
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
Styrene TX 5100 10184802
tert-Butyl alcohol TX 4420 10184802
tert-Butylbenzene TX 4445 10184802
Tetrachloroethylene (Perch loroethylene) TX 5115 10184802
Toluene TX 5140 10184802
trans-1,2-Dichloroethylene TX 4700 10184802
trans-1, 3-Dichloropropylene TX 4685 10184802
trans-1,4-Dichloro-2-butene TX 4605 10184802
Trichloroethene (Trichloroethylene) TX 5170 10184802
Trichlorofluoromethane TX 5175 10184802
Trichlorotrifluoroethane TX 5185 10184802
Vinyl acetate TX 5225 10184802
Vinyl chloride TX 5235 10184802
Xylene (total) TX 5260 10184802
Method EPA 8270
Analyte AB Analyte ID Method ID
1,2,4,5-Tetrachlorobenzene TX 6715 10185805
1,2,4-T rich lorobenzene TX 5155 10185805
1,2-Dichlorobenzene TX 4610 10185805
1,2-Diphenylhydrazine TX 6220 10185805
1,3,5-Trinitrobenzene (1 ,3,5-TNB) TX 6885 10185805
1,3-Dichlorobenzene TX 4615 10185805
1,3-Dinitrobenzene (1 ,3-DNB) TX 6160 10185805
1,4-Dichlorobenzene TX 4620 10185805
1,4-Naphthoquinone TX 6420 10185805
1-Naphthylamine TX 6425 10185805
2,3,4 ,6-Tetrachlorophenol TX 6735 10185805
2,4,5-Trichlorophenol TX 6835 10185805
2,4 ,6-Trichlorophenol TX 6840 10185805
2,4-Dichlorophenol TX 6000 10185805
2,4-Dimethylphenol TX 6130 10185805
Page 36 of 41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
1104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
2,4-Dinitrophenol TX 6175 10185805
2,4-Dinitrotoluene (2,4-DNT) TX 6185 10185805
2,6-Dichlorophenol TX 6005 10185805
2 ,6-Dinitrotoluene (2 ,6-DNT) TX 6190 10185805
2-Acetylaminofluorene TX 5515 10185805
2-Chloronaphthalene TX 5795 10185805
2-Chlorophenol TX 5800 10185805
2-Methyl-4 ,6-dinitrophenol TX 6360 10185805
2-Methylnaphthalene TX 6385 10185805
2-Methylphenol (o-Cresol) TX 6400 10185805
2-Naphthylamine TX 6430 10185805
2-Nitroaniline TX 6460 10185805
2-Nitrophenol TX 6490 10185805
2-Picoline (2 -Methylpyridine) TX 5050 10185805
3,3'-Dichlorobenzidine TX 5945 10185805
3 , 3'-Dimethylbenzidine TX 6120 10185805
3-Methylcholanthrene TX 6355 10185805
3-Nitroaniline TX 6465 10185805
4-Aminobiphenyl TX 5540 10185805
4-Bromophenyl phenyl ether TX 5660 10185805
4-Chloro-3-methylphenol TX 5700 10185805
4-Chloroaniline TX 5745 10185805
4-Chlorophenyl phenylether TX 5825 10185805
4-Methylphenol (p-Cresol) TX 6410 10185805
4-Nitroaniline TX 6470 10185805
4-Nitrophenol TX 6500 10185805
5-Nitro-o-toluidine TX 6570 10185805
7 , 12-Dimethylbenz(a) anthracene TX 6115 10185805
a-a-Dimethylphenethylamine TX 6125 10185805
Acenaphthene TX 5500 10185805
Page 37 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
Acenaphthylene TX 5505 10185805
Acetophenone TX 5510 10185805
Aniline TX 5545 10185805
Anthracene TX 5555 10185805
Benzi dine TX 5595 10185805
Benzo(a)anthracene TX 5575 10185805
Benzo(a)pyrene TX 5580 10185805
Benzo(b )fluoranthene TX 5585 10185805
Benzo(g , h, i)perylene TX 5590 10185805
Benzo(k)fluoranthene TX 5600 10185805
Benzoic acid TX 5610 10185805
Benzyl alcohol TX 5630 10185805
Biphenyl TX 5640 10185805
bis(~-Chloroethoxy)methane TX 5760 10185805
bis(2-Chloroethyl) ether TX 5765 10185805
bis(2-Chloroisopropyl) ether TX 5780 10185805
bis(2-Ethylhexyl) phthalate (DEHP) TX 6255 10185805
Butyl benzyl phthalate TX 5670 10185805
Carbazole TX 5680 10185805
Chlorobenzilate TX 7260 10185805
Chrysene TX 5855 10185805
Diallate TX 7405 10185805
Dibenz(a,h) anthracene TX 5895 10185805
Dibenzo(a ,e) pyrene TX 5890 10185805
Dibenzofuran TX 5905 10185805
Diethyl phthalate TX 6070 10185805
Dimethyl phthalate TX 6135 10185805
Di-n-butyl phthalate TX 5925 10185805
Di-n-octyl phthalate TX 6200 10185805
Dinoseb (2 -sec-butyl-4,6-dinitrophenol , DNBP) TX 8620 10185805
Page 38 of 41
' I
1
i
I
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fie.Ids of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
Ethyl methanesulfonate TX 6260 10185805
Fluoranthene TX 6265 10185805
Fluorene TX 6270 10185805
Hexachlorobenzene TX 6275 10185805
Hexachlorobutadiene TX 4835 10185805
Hexachloroethane TX 4840 10185805
Hexachloropropene TX 6295 10185805
lndeno(1,2,3-cd) pyrene TX 6315 10185805
lsophorone TX 6320 10185805
lsosafrole TX 6325 10185805
Kepone TX 7740 10185805
Methapyrilene TX 6345 10185805
Methyl methanesulfonate TX 6375 10185805
Naphthalene TX 5005 10185805
Nitrobenzene TX 5015 10185805
Nitroquinoline-1-oxide TX 6515 10185805
n-Nitrosodiethylamine TX 6525 10185805
n-Nitrosodimethylamine TX 6530 10185805
n-Nitroso-di-n-butylamine TX 5025 10185805
n-Nitrosodi-n-propylamine TX 6545 10185805
n-Nitrosodiphenylamine TX 6535 10185805
n-Nitrosomethylethylamine TX 6550 10185805
n-Nitrosomorpholine TX 6555 10185805
n-Nitrosopiperidine TX 6560 10185805
n-Nitrosopyrrolidine TX 6565 10185805
o,o,o-Triethyl phosphorothioate TX 8290 10185805
o-Toluidine TX 5145 10185805
Pentachlorobenzene TX 6590 10185805
Pentachloronitrobenzene TX 6600 10185805
Pentachlorophenol TX 6605 10185805
Page 39 of41
i
1
i
I
I
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
Phenacetin TX 6610 10185805
Phenanthrene TX 6615 10185805
Phenol TX 6625 10185805
Pronamide (Kerb) TX 6650 10185805
Pyrene TX 6665 10185805
Pyridine TX 5095 10185805
Safrole TX 6685 10185805
Method EPA 9012
Analyte AB Analyte ID Method ID
Amenable cyanide TX 1510 10193405
Total Cyanide TX 1635 10193405
Method EPA 9034
Analyte AB Analyte ID Method ID
Total sulfides TX 2010 10196006
Method EPA 9040
Analyte AB Analyte ID Method ID
Corrosiv ity TX 1615 10197203
pH TX 1900 10197203
Method EPA 9045
Analyte AB Analyte ID Method ID
pH TX 1900 10198400
Method EPA 9050
Analyte AB Analyte ID Method ID
Conductivity TX 1610 10198808
Method EPA 9056
Analyte AB Analyte ID Method ID
Bromide TX 1540 10199209
Chloride TX 1575 10199209
Fluoride TX 1730 10199209
Nitrate as N TX 1810 10199209
Nitrate-nitrite TX 1820 10199209
Page 40 of41
Texas Commission on
Environmental Quality
NELAP -Recognized Laboratory Fields of Accreditation
TestAmerica Laboratories, Inc. -Austin
14050 Summit Drive, Suite A100
Austin, TX 78728-7149
Certificate:
Expiration Date:
Issue Date:
T104704217-10-5
6/30/2010
3/29/2010
These fields of accreditation supercedeall previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.
Matrix: Solid & Hazardous Material
Nitrite as N TX 1840 10199209
Orthophosphate as P TX 1870 10199209
Sulfate TX 2000 10199209
Method EPA 9066
Analyte AB Analyte ID Method ID
Total phenolics TX 1905 10200609
Method EPA 9095
Analyte AB Analyte ID Method ID
Paint Filter Test TX 10312 10204009
Method Iowa OA-1 ; GRO
Analyte AB Analyte ID Method ID
Volatile Petroleum Hydrocarbons TX 10330 90016403
Method Iowa OA-2 ; ORO
Analyte AB Analyte ID Method ID
Extractable Petroleum Hydrocarbons TX 10331 90016607
Method SSA/ASA Part 3 :34
Analyte AB Analyte ID Method ID
Carbon , organic (Walkley-Black) TX 10340 SSA/ ASA Pt 3 :34
Method TCEQ 1005
Analyte AB Analyte ID Method ID
Total Petroleum Hydrocarbons (TPH) TX 2050 90019208
Method Tennessee EPH
Analyte AB Analyte ID Method ID
Total Petroleum Hydrocarbons (TPH) TX 2050 Tennessee EPH
Method Tennessee GRO
Analyte AB Analyte ID Method ID
Total Petroleum Hydrocarbons (TPH) TX 2050 Tennessee GRO
Page41of41
r
I
BOAR_D OF REGISTRATION
FOil.ENGINEERS AND LAND SUR_VEYOR._S
Be It Known That
Qtliutnu £. llurklin
HAVING GIVEN SATISFACTORY EVIDENCE OF THE NECESSARY QUALIFICATIONS WITH REGARD TO
CHARACTER, EDUCATION, AND EXPE!RIENCE AS REQUIRED BY THE CURRENT NORTH CAROLINA
ENGINEERING AND LAND SURVEYING ACT, WAS EXAMINED -DULY REGISTERED -AWARDED THIS
CERTIFICATE -AND IS HEREBY AUTHORIZED TO PRACTICE AS A
PROFESSIONAL ENGINEER
IN THE STATE OF NORTH CAROLINA
IN TESTIMONY WHEREOF: THE BOARD OF REGISTRATION ISSUES THIS CERTIFICATE
UNDER THE SEAL OF THE BOARD AND SIGNATURES OF THE CHAIRMAN AND SECRETARY
THIS 3RD DAYOF JULY 1985t . .
a~~"" ~~~..;.,/2._,, ~~Ji&<
8.0 NONDI SCRIMINAT ION
AH City contractors are re quired to comply with Chapter 17 . ·Human Relat io ns: Article Ill.
''D iscrimin ation," Division 3 , "Employm ent Practices: of the Code of th e City of Fort Worth ,
prohibiting discrimination in employment practic es. P ro vi der agrees that P rov ider, its
employees, officers, agent s, contractors or subcontractors , have fully compli ed with all
provisions of such Ordinance , and th at no employee. p articip ant , applicant, contractor or
subcontractor has been discriminated against according to th e terms of such Ord lnance by
Provider . its employees , officers , agents , contractor o r subcontractors herein .
CONTRACTOR:
Eastern Research Group , Inc. BY: Paula G. Fields
Company Nam e (prtnt er type name of signato ry)
Address
O+~-A,-~
(Signature)
89 50 Cal Center Dr.. #348
Sacramento. CA 9582 6 Principal Engineer
City . State. Zip Titl e (print or type )
9.0 CONFLICT OF INTEREST AFFA.DAVtT
STATE OF TEXAS
COUNTY OF TARRANT
§
§
§
KNOWN ALL BY THESE PRESENTS:
On behalf of ___ l: __ R __ G~--· ------1 swear or affirm:
1. That all financfal conflicts of i nterest with any offici al , emptoyee , or relative of any offici al
or employee have been disclosed in our company 's or organization 's Statement of
Qualifications package submitted to the City of Fort Worth.
2 . That all financial inte r ests a nd prior contracts (with a value in excess of $10 ,000) with
any company whose primary business is involved in the production . processing ,
transmission, or sales of natural gas has been disclosed in our company 's or
organization's Statement of Qualifications package submitted to the City of Fort Worth.
3. That the company or organization agrees to comply with the eth ical standards
promulgated as Tex.as Occupationa l Code Section §137.57 stated below in all of its
deaHngs w ith regards to the City of Fort Worth A ir Qualrty Study, regardless of whether
or not the subm itting company or organization is a profess ional engineeri ng firm :
Engineers Shall be Objective and Truthful
(a) Engineers shall issue statements only in an objective and truthful manner.
Engineers should strive to make affected parties aware of the engineers '
professional concerns r egarding particular actions or proj'ects, and of the
consequences of engineering decisions or judgments that are overruled or
disregarded.
(b) The issuance of oral or 1,vritten assertions in the practice of engineering shall
not be:
(1) fraudulent,
(2) deceitful, or
(3) misleading or shall not in any manner whatsoever tend to create a misleading
impre ssion
(c) The engineer shall disclose a possible conflict of interest to a potential or
current client or employer upon discovery of the possible conflict.
(d) A conflict of interest exists when an engineer accepts employment when a
reasonable probability exists that the engineer's own financial, business,
property, or personal interests may affect any professional judgment, decisions,
or practices exercised on behalf of the client or employer. An engineer may
accept such an employment only if all parties involved in the potential conflict of
interest are fully informed in writing and the client or employer confirms the
knowledge of the potential conflict in writing. An engineer in a conflict of interest
employment shall maintain the interests of the client and other parties as
provided by §137. 61 of thl's title (relating to Engineers Shall Maintain
Confidentiality of Clients) and other rules and statutes.
Company Name
Name of Duly Authorized Officer of the Compa y or Organization
SUBSCRIBED AND SWORN TO BEFORE ME by the said 5 «.~. < <,f: \~ S b ~ V'I
to which witness my hand and official seal on this \ i 1 ~ day of __ ('n. .... ·_ ...... =.ct.--"'f1-----, 2010.
Notary Public in and tor the State of Texas
Seal:
ATTACHMENT A
KEY STAFF RESUMES
MIKE PRING, Senior Environmental Engineer ,ERG
Mike Pring has more than 19 years of experience in the air quality consulting field , specializing
in criteria air pollutant (CAP) and hazardous air pollutant (HAP) emission inventories , New
Source Review (NSR) permitting, and Title V and Minor Source permitting.
EDUCATION
B.S., Environmental Engineering , University of Florida, Gainesville, FL , 1991.
EXPERIENCE
Senior Environmental Engineer, Eastern Research Group, Inc., 1996-Present.
Environmental Engineer, Radian International LLC , 1991-1996.
Laboratory Technician , U.S. EPA Acid Rain Laboratory , University ofFlorida, 1988-1991.
Laboratory Technician , CH2MHill, 1988.
SELECTED RELEVANT WORK EXPERIENCE
Development of an Emissions Inventory for Drilling Rig Engines for Texas. Managed ERG
project to support the Texas Commission on Environmental Quality (TCEQ) for preparation of a
state-wide drilling rig emissions inventory for 2008. Lead a team of engineers and scientists in
preparing survey materials, interviewing drilling rig owners and operators, compiling survey
results , preparing emission factors using U.S. EPA 's NONROAD model , and estimating state-
wide emissions ofNOx, VOC , CO, PM 10, S02 , and HAPs. Developed historical and future year
projected inventories for 2002 through 2021 based on historical drilling data and forecasted oil
and gas production activity.
Development of an Emissions Inventory for Upstream Oil and Gas Sources for Texas.
Managing ERG 's support to the TCEQ for preparation of an emissions inventory of upstream oil
and gas emissions sources including dehydrators, compressor engines, wellheads, oil/gas well
completions, pneumatic devices, turbines, storage tanks, equipment leaks, and loading racks.
Identification of the best emissions estimation methodology for each source type, preparation
and distribution of a survey to industry to collect the data needed to implement the methodology,
and development of an emissions inventory for CAPs and benzene, formaldehyde , toluene ,
ethylbenzene, and xylene from upstream oil and gas production sites.
Oil and Gas Air Permitting. Project Manager in ERG 's support to the Alaska Department of
Environmental Con servation (ADEC), the Indiana Department of Environmental Management
(IDEM), and the Allegheny County Health Department (ACHD) permitting programs. Provided
technical leadership and overall project management for the preparation of Prevention of
Significant Deterioration (PSD), Title V , and minor source air quality permits for large offshore
oil and gas exploration and production platforms, natural gas compressor stations, and natural
gas storage facilities. Estimated emissions, performed regulatory analysis , conducted Best
Achievable Control Technology (BACT) analysis, and drafted permit language ensuring
compliance with all requirements of the Clean Air Act and state air quality rules.
Air Toxics. Conducted on-site audits at semiconductor, pulp and paper, organic and inorganic
chemical, paint, and furniture manufacturing facilities to assess compliance with the Toxics
Release Inventory (TRI) and the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA) reporting requirements. Updated EPCRA reporting guidance for semiconductor,
printing, and presswood/plywood manufacturing operations by evaluating TRI data reported for
these industries and working with trade associations to develop source category distinctions,
process descriptions, and environmental release estimation methodologies. Updated guidance
documents to provide clear regulatory interpretation and reporting guidance for issues
problematic to these industries.
A-1
CLINTON E. BURKLIN, P.E., Principal Engineer ,ERG
Clint Burklin 's career has focused on the characterization of air pollutant emissions , the
evaluation of emission control equipment, and the support and development of emission
performance standards . This work has been in the form of technical assistance to national , State,
and local air control agencies, as well as direct technical assistance to electric utilities , energy
companies, the Electric Power Research Institute, the American Petroleum Institute and the Gas
Research Institute. Mr. Burklin's experience spans the full range of air pollutants including the
criteria pollutants, toxic air pollutants, ozone precursors, and greenhouse gases.
EDUCATION
B.S., Chemical Engineering, The University of Texas, Austin, TX, 1971.
EXPERIENCE
Vice President, Eastern Research Group, Inc., 2004-Present.
Senior Program Manager, Eastern Research Group , Inc., 1996-2004.
Principal Project Manager, Radian International LLC , 1994-1996.
Various engineering positions , Radian Corporation , 1971-1993.
SELECTED RELEVANT WORK EXPERIENCE
Oil and Gas GHG Protocol Development. For The Western Climate Initiative (WCI), Mr.
Burki in is leading a task to develop the mandatory GHG reporting protocol for the cap-and-trade
program. He works hand-and-hand with the oil and gas committee to establish accurate
quantification and monitoring methods, and investigate technical issues associated with complex
emission sources such as contractor emissions, storage tanks , field gas combustion , instrument
gas vented from pneumatic control devices, and others . He is leading the development of
regulatory language that is aligning the WCI reporting requirements with the federal mandatory
reporting rule , Subpart W requirements .
GasSTAR Program Support. Mr. Burklin directed a study under U .S . EPA's GasST AR program
(promoting voluntary methane reductions in the U.S. natural gas industry) that evaluated the
uncertainty in the annual methane reductions reported by the U.S. natural gas industry. The
methane emission estimation methodologies reviewed by Mr. Burklin applied to fugitive ,
exhaust, and direct methane emissions from equipment used by the production , processing,
transmission, and distribution sectors of the natural gas industry.
Update toAP-42 Emissions Factors/or Industrial Sources. Mr. Burklin has directed a series of
more than l O work assignments to develop and update the emission factors in U.S. EPA's
Compilation of Air Pollutant Emission Factors (AP-42). These studies resulted in new factors
and updated previous factors for toxic, criteria, and greenhouse gas emissions from petroleum
production and refining sources, gasoline storage and marketing, external combustion boilers and
heaters, and internal combustion engines and turbines.
Field Fuel Gas Combustion in NG Fields/or HARC. For the Houston Advanced Re search
Center (HARC) and the TCEQ, Mr. Burklin developed detailed inventories for stationary
reciprocating engines. In the first study, Mr. Burklin inventoried the natural gas engines used in
the gas fields to compress and transport natural gas to gas processing plants in Texas. The
inventory included collecting detailed information on over 1000 engines used in the Texas gas
fields and conducting site visits to 65 compression facilities to verify their inventory data. Mr.
Burki in developed an inventory of Texas gas field compressor engine emissions for the years
1999, 2000 and 2002 , and forecast emissions for the years 2007 and 20 l 0.
A-2
JOHN WILHELMI, Senior Chemical Engineer \\ERG
John Wilhelmi is a se nior chemical engineer in ERG's Environmental and Occupational Health
practice. He has devoted his professional career ( 16 years) to characterizing air emissions from a
wide array of industrial processes, evaluating their transport through the atmosphere, and
assessing potential inhalation exposures and health ri sks. For the past 14 years , Mr. Wilhelmi has
provided this service to the federal Agency for Toxic Substances and Disease Registry (ATSDR)
for dozens of sites, including some of the agency 's highest visibility projects.
EDUCATION
B.S., 1991 , Chemical Engineering, Stanford University.
M.S., 1996 , Chemical Engineering, Massachusetts Institute of Technology.
EXPERIENCE
Senior Chemical Engineer (Vice President), ERG , 1996-Present.
Re search Assistant, Massachusetts Institute of Technology, 1994-1996 .
Associate Consultant in Air Sciences, ENVIRON Corporation , 1991-1993.
SELECTED RELEVANT WORK EXPERIENCE
Public Health Evaluation of Air Emissions from Multiple Texas Petroleum Refineries.
Manages an ongoing project for the ATS DR to assess the public health implications of exposure
to air pollution in neighborhoods along so-called "Refinery Row " in Corpus Christi . Integrated
facility emission data from multiple sources, ambient air monitoring data, and dispersion
modeling data into a cohesive account of local outdoor air quality issues. Helped the agency
respond to community health concerns regarding both acute and chronic exposures to airborne
hydrocarbons and other pollutants. Prepared written documents for a wide range of audiences.
Public Health Evaluation of an Accidental Release from a Petroleum Refinery. Assisted
ATS DR in evaluating the public health implications of inhalation exposure to pollutants released
during an accidental release of catalyst from a cracking unit at a petroleum refinery in Wyoming.
Submitted detailed evaluations of typical refinery operations, facility-specific emission data,
dispersion modeling analyses, and toxicity reviews. Assisted A TSDR with preparing a public
health assessment, intended for public distribution later in 2010.
Data Quality Reviewer for U.S. EPA 's Toxics Release Inventory (TRI). Helped U.S. EPA
assess the accuracy of facility-specific environmental release data submitted to the agency's
Toxics Release Inventory. Conducted site visits to more than 40 industrial facilities-including
petroleum refineries in Texas-to assess the quality of air emissions data and waste management
data that were disclosed to the public.
Exposure Investigations for Oil and Gas Production Activities. Served as senior data reviewer
for multiple exposure investigations conducted under contract to A TSDR. All exposure
investigations involved ambient air monitoring of pollutants of interest, typically some
combination of hydrogen sulfide, sulfur dioxide, and volatile organic compounds. The exposure
investigation s were conducted to assess air quality impacts from a wide range of industrial
operations, including oil and gas production activities, refineries , landfills, and electricity
generating facilities.
Public Health Evaluation of Cement Kilns. Providing ongoing technical assistance to ATSDR
on its evaluation of the public health implications of exposure to air pollutants released by three
large cement kilns in Midlothian, Texas. Examined spatial and temporal trends among emission
data ( continuous and annual) and conducted an extensive data quality review of ambient air
monitoring data.
A-3
ARNOLD R. SRACKANGAST, Mid-Level Scientist 'ERG
Mr. Srackangast has 21 years experience in managing, performing, and peer reviewing
atmospheric modeling studies in support of federal and State air quality evaluations. Mr.
Srackangast is a recognized expert on the development, application , and use of atmospheric
dispersion models, as well as other air quality topics, including ambient monitoring, emission
inventory development and meteorological data processing.
EDUCATION
B.S. (Cum Laude), Meteorology, Texas A&M University, 1985.
EXPERIENCE
Principal Scientist, Eastern Research Group, Inc., 2003-Present.
Independent Contractor, AS 1 MET Services, 2003-Present.
URS Corporation / Radian International LLC / Radian Corporation , 1985-2002.
SELECTED RELEVANT WORK EXPERIENCE
Co-Generation Air Quality Analysis. Lead technical review of the air quality analysis of a 2100
MW natural gas-fired cogeneration project sited near Gila Bend , AZ , for the Maricopa County
Environmental Services Department. Performed technical peer review of the modeling protocol
and application, including federal Class I and Class ll impacts, and participated in public hearing
support.
Permit Timeline Reduction Initiative Modeling Support. Subcontractor for the University of
Texas Center of Energy and Environmental Resources (UT/CEER) on a contract with TCEQ to
provide air dispersion modeling support under the Permit Timeline Reduction Initiative.
Conducted air dispersion modeling for six facilities in order to expedite the permitting process
for RCRA hazardous waste combustion facilities. Performed modeling in accordance with the
procedures described in the U.S. EPA 's "Human Health Risk Assessment Protocol."
Co-Generation Facility Modeling. Task member for the air quality analysis portion of an
Application for Certification of a 320 MW Cogeneration and Power Project. Served as internal
technical consultant and peer review on air dispersion modeling and meteorological processing.
Provided expert testimony at public hearings before the California Energy Commission (CEC).
NAAQS and PSD Modeling. Task leader in charge of performing full NAAQS and PSD analysis
for five Tier Il Gasoline projects in the Gulf Coast Region . Comprehensive facility information
was gathered and compiled , including sitewide building downwash information , as well as
developing PSD baseline and current emission rates for increment analyses. Off-site emission
retrievals were reviewed for errors and omissions.
Ozone Formation and Transport Study. Task leader for a major analysis of the formation and
transport of ozone in the Houston , Texas area. Research led to the development of an ozone
climatology of the region. Responsibilities included analyzing and correlating meteorological
conditions during ozone episodes, performing air quality and meteorological data analyses,
designing and development of computer generated graphics for data presentation , and the
upgrade and maintenance of a large 5-year air quality database of 33 continuous air monitoring
stations in the Houston area. Also developed forward and back trajectories to determine the
transport of ozone on individual days.
Meteorological Data Collection. Task leader of a project to collect and process annual on-site
meteorological data from two 30-meter meteorological towers and National Weather Service
observations into the format necessary for air dispersion models , including AERMOD, ISCST3 ,
and COM.
A-4
REGI OOMMEN, Senior Scientist ,ERG
Regi Oommen is a senior scientist with more than 14 years of experience in the air quality
consulting and emission inventory development, specializing in database management, quality
assurance/quality control , and data analyses of criteria air pollutants (CAPs) and hazardous air
pollutants (HAPs).
EDUCATION
M.S., 1996 , Atmospheric Sciences, North Carolina State University.
B.S., 1994 , Meteorology , North Carolina State University.
B.A., 1994, Chemistry , North Carolina State University.
EXPERIENCE
Senior Scientist, Eastern Research Group, Inc., 2006-Present.
Environmental Scientist, ERG , 1996-2005
Environmental Chemist, North Carolina 's Division of Air Quality, 1996
SELECTED RELEVANT WORK EXPERIENCE
Development of Version 2 of the 2005 NATA National Emissions Inventory. Recently directed
the compilation and revision of Version 2 of U.S. EPA 's 2005 NATA National Emissions
Inventory (NEI) for point sources emitting HAPs and CAPs. Oversaw a team of scientists and
engineers by quality assuring the submitted data; blending and merging data from federal , state,
local , and tribal agencies ; and preparing emission data records in U.S . EPA 's NE[ Output Format
(NOF). Managed the development of the final database, which consisted of over 5.3 million
emission records. Prepared summary data files for state/local/tribal agency review.
Development of the 2005 Oil and Gas Emission Inventory for TCEQ. Developed CAP
emission estimates of area source oil and natural gas operations occurring in Texas for base year
2005. Reviewed emission factor, activity data, and control information for exploration processes
(e.g., well completions, mud degassing, offshore platforms) relating to oil and natural gas
production. Compiled the project database and formatted emissions in U.S. EPA 's NEI Input
Format (NIF) for the 2005 base year, and for projected emissions out to 2020 . ·
Exposure Investigations for ATSDR. Led data analysis tasks for the Agency for Toxic
Substances and Disease Registry 's (ATSDR) Exposure Investigations in: Plymouth , NC;
Lovington, NM; Overland Park, KS ; and Bridgeport, [L. Summarized results from ambient
monitoring for air toxics and harmful sulfur compounds, which included: statistical
characterization of the measurements from the monitoring network, evaluating the effect of
nearby stationary and mobile emission sources, construction of back trajectories and pollution
ro ses, and correlation to meteorological parameters. impacted communities were affected by oil
and natural gas sources, a pulp and paper mill , and a landfill.
Oil and Natural Gas Platforms for Gulf of Mexico Emissions Inventory. Oversaw the
development of the 2008 base year emissions inventory of CAPs and greenhouse gas (GHG)
from nearly 4,000 oil and natural gas platforms. Prepared activity data templates for operators to
populate and compiled survey data from the platform operators. Quality assured survey data
through identification of missing values; testing submitted data within acceptable range checks;
recalculation of total fuel used; corrections of the emissions estimation calculation program in
Oracle; and checking final emission estimates. Prepared final estimates of over two million
emission records in a format compatible for modeling. Performed similar tasks in preparation of
baseyear 2005 and 2000 emission inventories.
A-5
RAYMOND MERRILL, Senior Analytical Chemist -.ERG
Dr. Raymond Merrill is an internationally recognized environmental chemist with more than 33
years of experience managing and performing environmental measurements, methods
development, method evaluation, and quality control /quality assurance programs.
EDUCATION
Ph.D ., Analytical Chemistry, Duke University, Durham , North Carolina, 1977 .
B.S., Cum Laude, Chemistry , Stetson University, Deland , Florida, 1972.
EXPERIENCE
Senior Program Manager, Eastern Research Group, Inc., 1996-Prese nt.
Senior Program Manager, Radian Corporation , 1992-1996 .
Program Manager, Radian Corporation, 1990-1992.
Senior Staff Scientist, Group Leader, Radian Corporation , 1987-1990 .
Senior Scientist, Radian Corporation , 1986-1987.
Research Chemist, GS-14 , U.S. Environmental Protection Agency, 1983-1986.
Chemist, GS-13 , U.S. Environmental Protection Agency, 1980-1983.
Chemist, GS-I 2 , U.S. Environmental Protection Agency, 1978-1980 .
Research Associate/Research Fellow, Duke University, 1976-1978.
SELECTED RELEVANT WORK EXPERIENCE
Stationary Sources Audit Program. Manages development and distribution of QA performance
evaluation and audit samples to states and regions for use in compliance test evaluation projects .
Manages and serves as peer reviewer for development and improvement of sampling and
analysis methods for toxic compounds on U.S. EPA 's high priority list of 33 toxic chemicals.
Cement Kiln NOx Reduction Strategies. Managed Ellis County Cement Kiln NOx Reduction
Strategies, Composition of Ellis County Raw Materials. Directed chemical analysis team and
subcontractors to conduct research to determine the chemical, mineral and elemental
composition of limestone and all other raw materials used in clinker production in Ellis county
including, sulfur, organic content, calcite, dolomite, aragonite and pyrite Significant differences
were identified in raw materials to explain variability in NOx emissions.
Estimating VOC Emissions from Animal Waste Lagoons Using the WATER9 Model.
Prepared work plan , Quality Assurance Project Plan (QAPP), and special head space protocol for
U.S. EPA review. Manages ongoing work to investigate total organic (non-methane/non-ethane)
carbon mass ; analyze swine waste sample head space for VOCs and total non-methane/non-
ethane carbon mass ; analyze swine waste samples for volatile, semivolatile, and tentatively
identified organics using RCRA SW-846 methods; and analyze swine waste samples for selected
polar organic compounds (POC) using direct aqueous injection of samples following the research
protocol developed by U.S . EPA/NE[C.
Cavity Ring Down Spectroscopy (CRDS) Large Area Mobile Monitoring Method Evaluation.
Prepared work plan , QAPP, and executed a field test evaluation of CRDS technology combined
with tracer release to estimate emission flux from a large area municipal landfill.
Passive Fourier Transform Infrared Spectroscopy (PFTIR) for U.S. EPA. Prepared work plan,
QAPP, and prepared for field test to evaluate PFTIR technology at an industrial flare facility
scheduled for August 20 I 0.
A-6
DAVE DAYTON, Senior Environmental Engineer '-ERG
Dave Dayton is a Senior Environmental Engineer and Senior Program Manager. During his 35
years in the environmental field , Mr. Dayton has participated in and directed a wide range of
programs, primarily in the areas of modeling analysis, ambient air quality monitoring
technologies, monitoring program design , remote sensing technologies, instrumentation and
systems design , method research and de velopment, gas chromatography, mass spectrometry, and
stationary source emissions monitoring.
EDUCATION
Mechanical Engineering, North Carolina State University.
EXPERIENCE
Senior Program Manager/Senior Engineer, Eastern Research Group, Inc., 1997-Present.
Senior Engineer, Eastern Research Group , Inc., 1996-Present.
Senior Scientist, Radian International , LLC , 1994-1996.
Group Leader, Radian Corporation , 1991-1993.
Staff Engineer, Radian Corporation , 1988-1991.
Engineer, Radian Corporation , 1983-1988.
Member of Technical Staff, TRW Corporation, 1980-1983.
Research Assistant, Research Triangle Institute, 1974-1980.
Environmental Technician , U .S . Environmental Protection Agency, 1972-1974.
SELECTED RELEVANT WORK EXPERIENCE
U.S. EPA 's National Monitoring Programs. Serves as Contract Manager and Senior Program
Manager for multiple U.S. EPA /OAQPS delivery order contracts to support multiple nationwide
ambient air networks, such as the Non-Methane Organic Compounds (NMOC), Speciated
NMOC (SNMOC), urban air toxics monitoring program (UATMP), photochemical assessment
monitoring stations (PAMS), and the National Air Tox ics Trends Stations (NA TIS) monitoring
efforts. Support included equipment design and fabrication , installation and operation assistance
(i.e., for canister sample and carbonyl compounds collection), training , sample analysis, data
reporting , and entry of data into the AQS database. Contracts have spanned 17 years of
continuous monitoring network operation.
Agency for Toxic Substances and Disease Registry (ATSDR) Exposure Investigations. Served
as Senior Program Manager for multiple ambient air monitoring networks in Plymouth, NC ,
Lovington , NM, Overland Park, KS , Bridgeport, IL , Alexandria, VA , and Thomaston , ME.
Developed network design plan , monitoring plan , and data analyses plan for sampling of
hydrogen sulfide, ammonia, hazardous air pollutants, and/or criteria air pollutants at locations
that could impact public health.
San Joaquin Valley Air Quality Study (SJVAQS). Served as Project Director for the SJVAQS.
Designed , fabricated , tested , and demonstrated an automated nonmethane organic compound
(NMOC) monitoring instrument. The system is semi-continuous and based on U.S. EPA
Reference Method T0-12. The system was used to collect NMOC data at the Edison , California
site during the study.
Emissions Sampling -Boiler Industrial Furnaces (BIF). Serves as Program Manager to
support network monitoring efforts around two BIF facilities. Data from these networks were
used to develop criteria for BIF permitting. Support included equipment installation and
operation assistance (i.e., for high-volume particulate, high-volume semivolatile, volatile organic
compounds, total organic compounds, and meteorology), sample analysis, and data reporting.
A-7
SCOTT FINCHER, Staff Scientist '-ERG
Mr. Fincher is a Staff Scientist. He assists with processing and analysis of data in support of air
quality projects. Mr. Fincher 's areas of experience included dispersion modeling for several
petrochemical , lumber, electrical generation, and U.S. military facilities . In addition, he provided
deposition and dispersion modeling in support of indirect risk assessments. He has also assisted
in retrieval , analysis, and processing of meteorological data when necessary. Mr. Fincher
currently uses his background in dispersion modeling to review and comment on modeling
anal y ses submitted in support of permit applications for a number of state agencies.
EDUCATION
B.S., Meteorology, Tex as A&M University, College Station , TX., 1998.
EXPERIENCE
Staff Scientist, Eastern Re search Group, Inc., 2008-Present.
Scientist, Eastern Research Group, Inc., 2003-2008.
Meteorologist, URS Corporation , Austin , TX, 2000-2003.
Associate Meteorologist, Radian International , Austin , TX , 1998-2000.
SELECTED RELEVANT WORK EXPERIENCE
For both the Arizona Department of Environmental Quality (ADEQ) and the Alaska Department
of Environmental Conservation (ADEC), Mr. Fincher performed reviews of modeling protocols
and modeling report submitted to the respective states. He conducted completeness reviews ,
evaluated AERMOD model inputs and outputs for conformance with state modeling regulations,
and prepared memos for state use summarizing findings .
Deposition and Air Dispersion Modeling. Performed modeling that conformed to U .S . EPA
guidance , in support of seven indirect risk assessments for various hazardous waste incinerator
and electric utilities. He also revised an indirect risk assessment work plan to comply with the
U .S. EPA "Human Health Risk Assessment Protocol" for hazardous waste combustion facilities .
Permit Modeling. Modeling task leader for an air permit for a major Gulf Coast client. He
performed SCREEN3 and ISCST3 modeling, and was responsible for full task documentation.
Additionally, he provided follow-up technical assistance as this permit went to hearing before the
TNRCC.
Air Quality Modeling Support. Mr. Fincher served as a modeling task leader or team member
for more than thirty additional projects in the States of Texas, Louisiana, Mississippi , New
Mexico, Nebraska, Wyoming, Tennessee , and Ohio. These include electrical cogeneration
facilities and power plants, U.S . military facilities , several Gulf Coast petrochemical clients, and
various lumber processing facilities in support of Federal and State permitting efforts. He was
responsible for SCREEN3 , OCD, ISCST3 , and AERMOD modeling, full task documentation ,
and QC of modeling inputs.
Model Training. Provided training to a U.S. Government contractor in the setup and use of the
NASA Chemical Equilibrium with Applications (CEA) model. He also provided subsequent
s upport to the contractor as the CEA model was used in open burning/open detonation (OB /OD)
applications.
A-8
SAGE
ENVIRONMENTAL CONSULTING
DAVID RANUM, Senior Technical Specialist "Friendly Sen,ice, No Surprbe,!"
David has over 27 years experience in a variety of areas within the environmental field,
including instrumentation system design , air toxics monitoring, auditing of environmental
systems, water monitoring, fugitive emissions monitoring, stack testing using CEMs (Continuous
Emission Monitors) and , design and installation of CEM systems and ambient air monitoring
using conventional analyzer systems and FTIR (Fourier Transform Infrared Spectroscopy)
technologies. His skills include instrumentation operation, maintenance, calibration , and repair,
environmental sampling, technical writing, data processi ng , project management, and the
auditing of ambient air monitoring systems and LOAR (Leak Detection and Repair) programs.
Mr. Ranum provided repair and field service s upport of microprocessor-based data acquisition
systems for Radian Corporation (now part of URS Corporation). He later transferred to Radian 's
Air Monitoring Department where he provided instrumentation , quality control , reporting and
auditing support on a wide variety of projects associated with both ambient and process level
emission measurements. Before leaving URS , David worked with the FTIR group in the
application of this new technology to environmental measurements as well as participating in
numerous U.S. EPA Consent-Decree mandated LOAR audits.
David moved to Sage Environmental Consulting in December 2005 where he continues to work
on LOAR projects as well as extend Sage's expertise and capabilities in the areas of ambient air
and source level monitoring . David's recent activities have included performing LOAR audits,
conducting IR camera surveys at both off-shore and on-shore facilities, designing and conducting
Level 1 Thermography Certification training, conducting direct emission testing (bagging), and
support of a meteorological system he installed at a landfill site in Oregon.
Experience Summary
• Performed an IR camera survey of a Gulf Coast natural gas facility in response to odor
complaints in early 2010.
• Installed a meteorological system at a landfill site in Oregon in 2009-20 I 0. Provided operator
training and continued support.
• Conducted an IR camera survey for 1-3 butadiene emissions at a Gulf Coast refinery in 2009.
• Performed an lR camera survey for leaking equipment at two Shell-owned off-shore
platforms in 2009.
• Project Manager and lead auditor in numerous Consent Decree LOAR audits.
• Project Manager for a nine-month IR camera study at a mid-sized Texas refinery in 2007-2008.
• Conducted direct emission testing (bagging) in support ofIR camera studies in 2009-20 l O for
Battelle Memorial Institute as well as several similar bagging studies .
• Provided instrumentation support for numerous source level and ambient air monitoring
programs.
• Conducted flu x chamber emission testing on both land farms and surface impoundments.
• Provided technical support in numerous FTIR-based source and ambient level monitoring
programs.
Education
Electronics Technician Diploma, Southwest School of Electronics, Austin , TX 1978 .
Secondary Education Diploma, the University of Victoria, Victoria, Briti s h Columbia 1975.
M.A. English Literature, the University of Washington , Seattle, WA . 1972 .
B.A. Honors, English Literature, the University of Victoria, Victoria, British Co lumbia, 1971.
A-9
SAGE
ENVIRONMliNTAL CONSULTING
ARTHUR V. BEDROSIAN, Key Executive Advisor "Friendly Service, No Surprise,!"
With 39 years experience in the environmental profession , Art Bedrosian has served as a
meteorology officer in the U.S. Air Force, has worked for the Texas Air Control Board , and has
been an engineering and environmental consultant for more than 30 years. As a member of the
Board of Directors of the Central Texas Clean Air Force and Chair of the Technical Advisory
Committee, Mr. Bedrosian has and continues to work closely with business leaders, elected
officials, and regulators. He has provided community leadership in the evaluation of air quality
impacts, as well as point and area source emissions reductions methods to reduce ozone levels in
Tex as. Since the regional efforts began in 1995 , he has been actively engaged in shaping the
direction of the technical efforts to develop an accurate emissions inventory database ,
representative photochemical modeling , and realistic mitigation measures.
Experience Summary
• Successfully evaluated regional ozone issues for the Texas Air Quality Coalition , a IO-county
area north of Dallas. The project goal was to identify and develop mitigation measures aimed
at ozone reduction for the Dallas-Fort Worth non-attainment area.
• Established and managed an ambient air monitoring project which involved data collection ,
data reporting, and quality assurance for a six-month long program to develop a carbon
monoxide and meteorological data base for two major roadway intersections in New York
City . This effort utilized four 10-meter meteorological towers and eight carbon monoxide
monitors in two urban canyon settings.
• Managed a one-year long PSD air monitoring program to establish a pre-construction ambient
air quality baseline for Champion Paper's proposed paper mill in East Texas. This continuous
monitoring effort involved five NAAQS parameters plus meteorology. Mr. Bedrosian was
responsible for all data reports and quality assurance documentation.
• Managed the operation, data reporting , and quality assurance for three one-year long multi-
station TSP and meteorological monitoring programs for proposed lignite surface mines in
Louisiana and Texas.
• While employed by the TACB (now TCEQ), Mr. Bedrosian was responsible for the
management of the data collection and equipment maintenance for twenty-three Texas Air
Surveillance Network monitoring sites and four Continuous Air Monitoring Stations. He
participated in monitor site selection and used monitored data to assist in control strategy
development, State [mplementation Plan consistency determinations, and selection of
Attainment/Non-attainment determinations. He coordinated TACB monitoring activities with
those of contractors during the 1977 Houston Area Ox idant Study.
• Performed PSD pre-construction ambient air quality and meteorological monitoring station
siting studies for New Mexico Power and Light 's Red Bluff coal-fired generating station and
another in West Texas for Texas Utilities .
• Designed a sampling program to quantify sulfuric acid emission levels from a large golf cart
battery charging facility and a program to quantify methane emissions from a landfill. While
with the T ACB , he performed vinyl chloride and benzene sampling at selected industries
along the Houston Ship Channel.
• Performed source sampling for particulate matter, heavy metals, and sulfur dioxide at oil
refineries , petrochemical facilities , foundries, power plants , and manufacturing facilities .
Education
B.S. in Physics , Stevens Institute of Technology.
U .S. Air Force, Meteorology Training, 43 Semester Hours , Texas A&M University.
A-10
SAGE
ENVIRONMl:NTAL CONSULTING
JENNIFER PARRAS, Project Manager "Friendly Service, No Surpruu!"
Jennifer has experience in the environmental field focused on air quality , water and waste
compliance, as well as solid waste management. Jennifer 's air quality experience includes Title
V operating permitting, New Source Review permitting, Flexible Permitting, Permits by Rule,
Standard Permits, Title V Compliance Certification reporting, regulatory analysis, state and
federal emissions reporting requirements, environmental rule interpretation and general
environmental reporting for refineries , natural gas processing facilities , and asphalt
manufacturing operations. Her water and waste water ex perience included the implementation
of new Spill Prevention Control and Countermeasure (SPCC) rules , New Mexico Pit and Below
Grade Tank Rule , and Stormwater Pollution Prevention Plan (SWPPP) Regulations. Her solid
waste ex perience focused on managing all land disposal units on site and auditing offsite land
disposal facilities.
Experience Summary
• Worked for Sage since June 2005 where she has been responsible for compliance
implementation and permitting including various NSR permits , excess emissions auditing,
Benzene NESHSAPs third party review and TAB generation, RCRA auditing, & SPCC
review and plan corrections.
• Worked for Duke Energy Field Services, in Midland , TX (2001 -2005) where her duties
included environmental compliance of the Western Division Area (includes 18 Gas Plants and
300 compressor stations located in New Mexico and Texas); management of a staff of 4
environmental professionals and l administrative assistance ; compliance with all air, water,
and waste issues; consultation with legal ; serving as lead auditor for internal corporate
environmental audits ; and acting interface between management and filed operations
personnel.
• Served as the Environmental Group Leader for Alon USA LLP, in Big Spring, TX. There she .
was responsible for the environmental management of all Alon USA facilities including the Big
Spring Refinery , 6 terminals, pipelines, and fuels , as well as miscellaneous corporate issues.
• Worked as an Environmental Engineer for Fina Oil & Chemical Company (Big Spring
Refinery), Big Spring, TX. Her responsibilities included stewarding the LOAR program ,
submitting periodic compliance reports for regulated air emissions, developing compliance of
the applicable units for MACT and NSPS Regulations, developing and submitting the AEI
and TRI reports , management of the Title V , report daily reportable emissions to the proper
agencies, and providing environmental guidance on any environmental issues within the
process units.
• Performed emission control sampling of wastewater for analysis of total hazardous air
pollutants, and sampling of refinery products for volatile organic compounds.
• Developed refinery and gas plant Title V compliance demonstration tools.
• Developed Title V permit amendments and annual reports.
• Developed maintenance startup and shutdown permit application for refineries.
• Provided various permit by rule registrations for oil and gas companies.
• Conducted excess emissions rules/regulations and engineering analysis for natural gas
facilities in Texas and New Mexico.
• Conducted New Mexico excessive emission reporting review and engineering analysis.
Education
B.S. Environmental Engineering, Montana Tech, Butte, MT , 1995
A-11
SAGE
ENVIRONMENTAL CONSULTING
HARISH BADRINARA YANAN, Technical Specialist "Friendly Service, No Surpri,es!"
Harish has over nine years of experience in the environmental consulting focused on air quality
compliance. He specializes in providing technical and regulatory support on compliance issues.
Harish has assisted oil and gas companies in bringing their sites in Texas into compliance
through significant air permitting efforts resulting from voluntary audit disclosures. He has
experience in providing on-site support for continuous compliance for upstream and midstream
oil and gas facilities. He has prepared emissions inventories and handled various aspects of Title
V and NSR air permit applications including emission calculations, rule interpretation , and forms
preparation.
Experience Summary
• Prepared emission inventories for natural gas compressor facilities located in states of Kansas,
New Mexico, and Colorado and a Natural Gas Liquids (NGL) facility in Washington.
Prepared Annual Compliance Certifications (ACC) and Semi-annual monitoring reports
(SAR) for facilities located in Colorado. Prepared Notice of Intent (NOi), portable and
stationary Streamline Permit applications for co-located natural gas compression facilities
located in New Mexico. Prepared summary of historical Greenhouse Gas (GHG) emissions
for all reporting units at the performance unit level. (BP West Lake).
• As part of a voluntary audit disclosure, managed and supported preparation of Permit By Rule
(PBR), Standard Permits (SP), and case-by-case New Source Review (NSR) permit
applications to accurately permit compressor stations and gas processing plants. Estimated
emissions from combustion sources, blowdown operations, condensate flashing ,
miscellaneous VOC storage tanks, truck loading, dehydration units , and fugitive emissions.
Interacted with legal personnel to develop strategies to demon strate compliance with audit
disclosure items. Familiar with the use of software such as E&P TANKS, GRI-GLYCALC ,
and U.S. EPA TANKS 4.09 and simple SCREEN3 modeling . (Eagle Rock Energy, DCP
Midstream, Enbridge)
• Worked extensively in preparing permit by rule and standard exemption applications for
authorizing emissions from new sources and for permitting grandfathered sources. Worked
on authorizing emissions from sources such as analyzers, flares , fugitive components, diesel
engines, surface coating facilities, loading/unloading facilities and adsorption units. He has
prepared documents and templates for PBRs and Standard Exemptions (SEs) in order to
comply with the recordkeeping requirements of 30 TAC 106.8. Reviewed all PB Rs and SEs
at facilities and developed recordkeeping templates to demonstrate continuous compliance
with the requirements of the PBR. (Chevron Phillips Chemical Company-Port Arthur facility,
EI DuPont de Nemours, B eaumont Works Facility)
• Prepared federal air operating (Title V) permit applications and updates for petrochemical ,
polymer manufacturing and chlor-alkali facilties. Reviewed potentially applicable federal
(NSPS, NESHAP, and MACT standards) and state regulations . Determined applicability of
regulations and completed all relevant forms. Prepared relevant Title V application forms
using Intelliregs software. (Chevron Phillips Chemical Company-Port Arthur and Orange
facilities , No ltex LLC, OxyVinyls Battleground Facility)
Education
• MBA , University of Houston -Victoria, Texas, December 2009
• M.S. in Environmental Engineering, Texas A&M University-Kingsville, Texas 2001
• B.S. in Chemical Engineering, Madras University, Chennai, lndia 1999
A-12
Drilling Rig Emission
Inventory for the State of
Texas
Final Report
Prepared for:
Texas Commission on Environmental
Quality
Prepared by:
Eastern Research Group, Inc.
July 15, 2009
Drilling Rig Emission Inventory for the State of Texas
Final Report
Prepared for:
Greg Lauderdale
Texas Commission on Environmental Quality
P . 0 . Box 13087
Austin, TX 78711-3087
Prepared by:
Rick Baker
Mike Pring
Eastern Research Group , Inc.
5608 Parkcrest Drive, Suite 100
Austin, TX 78731
July 8, 2009
Table of Contents
LIST OF ACRONYMS ................................................................................................................. iii
1.0 Exec utive Summary ......................................................................................................... 1-1
2.0 Introduction ...................................................................................................................... 2-1
3.0 Re view of Existing Literature .......................................................................................... 3-1
3.1 Re view of Existing Studies .................................................................................. 3-1
3.2 Review of Existing Data ...................................................................................... 3-2
3.3 Drilling Rig Overview ......................................................................................... 3-3
4.0 Data Collection Plan ........................................................................................................ 4-1
4.1 Participant Recruitment ....................................................................................... 4-1
4 .2 Phone/Email Surveys ........................................................................................... 4-1
4.3 Confidentiality ..................................................................................................... 4-2
5.0 Data Collection Results .................................................................................................... 5-1
5 .1 Survey Findings ................................................................................................... 5-1
5.2 Model Rig Category De ve lopment ...................................................................... 5-3
5.3 Fracturing ............................................................................................................. 5-6
6.0 Emissions Inventory Dev elopment and Re su lts .............................................................. 6-1
6 .1 Activity Data ........................................................................................................ 6-1
6.1.1 2008 Base Year Activity .......................................................................... 6-1
6.1.2 2002 and 2005 Prior Years Activity ........................................................ 6-1
6.1.3 2009 through 2021 Projected Activity ..................................................... 6-3
6 .1.4 2002 , 2005, and 2008 through 2021 Activity Summary .......................... 6-6
6.2 Model Rig Emission Profiles ............................................................................. 6-12
6.2.1 Model Rig Engine Profiles ..................................................................... 6-12
6.2.2 Model Rig Emission Factors .................................................................. 6-14
6.3 Emission Estimation Methodology .................................................................... 6-17
6.4 Results ................................................................................................................ 6-19
6.4 .1 Emission Summary ................................................................................ 6-19
6.4.2 NIF 3.0 Files .......................................................................................... 6-19
7.0 Conclusions and Recommendations ................................................................................ 7-1
8.0 Reference s ........................................................................................................................ 8-1
Appendix A -Approved Data Collection Plan
Appendix B -Survey Letter
Appendix C -Drill Rig Survey Form
Appendix D -Survey Data
Ap pendix E -Total Drilling Depth by County by Model Rig Well Type Category
Appendix F -Emissio n Factors
Appendix G -Annual and OSD County-Level Emission Estimates
List of Tables
Table 1.1 Drilling Rig Estimates (tons /ye ar) ............................................................................... 1-2
Table 3.1 Existing Oil and Gas Exploration Emissions Studies .................................................. 3-1
Table 5.1 Survey Summary Statistics .......................................................................................... 5-3
Table 5.2 Model Rig Category Statistics ..................................................................................... 5-5
Table 6.1 2002 and 2005 Prior Year Activity Scaling Factors .................................................... 6-3
Table 6.2 Projected Crude Oil Production 2008-2021 ................................................................. 6-5
Table 6.3 Projected Natural Gas Production 2008-2021 ............................................................. 6-5
Table 6-4 Projected Growth Factors 2009-2021 .......................................................................... 6-7
Table 6.5 2008 Total Depth by Model Rig Well Type Category (1 ,000 feet) ............................. 6-8
Table 6.6 Model Rig Engine Parameters ................................................................................... 6-14
Table 6.7 PM 10 Speciation Factors ............................................................................................ 6-16
Table 6.8 TOG Speciation Factors ............................................................................................. 6-16
Table 6. 9 TxLED Counties ........................................................................................................ 6-17
Table 6.10 Texas Drilling Rig Estimates (tons /year) ................................................................. 6-20
Table 6.11 2008 Annual and OSD County-Level Criteria Pollutant Emission Estimates ......... 6-21
List of Figures
Figure 5.1 Counties with Survey Data ......................................................................................... 5-4
Figure 6.1 TRC District Map ....................................................................................................... 6-2
Figure 6.2 EIA Regions ............................................................................................................... 6-4
11
Acronym
API
CARB
co
DOE
EIA
ERG
HAP
hp
IADC
MMBBL
NEI
NIF
NOx
OSD
PM10
PM2 .s
sec
SIP
S02
TCEQ
TexAER
TIPRO
TOG
TRC
TxLED
TXOGA
US EPA
voe
WRAP
LIST OF ACRONYMS
Definition
American Petroleum Institute
California Air Resources Board
Carbon Monoxide
U.S. Department of Energy
Energy Information Administration
Eastern Research Group
Hazardous Air Pollutant
Horsepower
International Association of Drilling Contractors
Million Barrels
National Emissions Inventory
NEI Input Format
Nitrogen Oxides
Ozone Season Daily
PM with particle diameter less than 10 micrometers
PM with particle diameter less than 2.5 micrometers
Source Classification Code
State Implementation Plan
Sulfur Dioxide
Texas Commission on Environmental Quality
Texas Air Emissions Repository
Texas Independent Producers and Royalty Owners Association
Total Organic Gases
Texas Railroad Commission
Texas Low Emission Diesel
Texas Oil and Gas Association
United States Environmental Protection Agency
Volatile Organic Compounds
Wes tern Regional Air Partnership
lll
1.0 Executive Summary
The purpose of this study was to develop a comprehensive emissions inventory for
drilling rig engines associated with onshore oil and gas exploration activities occurring in Texas
in 2008. Oil and gas exploration and production facilities are considered some of the largest
sources of area source emissions in certain geographical areas, dictating the need for continuing
studies and surveys to more accurately depict these activities. A 2005 base year oil and gas
emissions inventory developed for the Texas Commission on Environmental Quality (TCEQ) by
Eastern Research Group (ERG) in 2007 (TCEQ , 2007) was comprehensive in coverage of all
exploration and production facility and equipment types, including drilling rig engines. However,
that project relied on data from secondary sources with assumptions applied to represent local
activities . The Western Regional Air Partnership (WRAP) developed a comprehensive emissions
inventory of oil and gas exploration and production facilities for the western states that did not
include Texas, although the previous ERG study did make use of the WRAP results in terms of
methodology and emission factors where practicable.
The current inventory effort built off of the previous 2007 study, focusing exclusively on
drilling activities . The previous effort was expanded upon by improving both the activity data
(well counts, types, and depths) used to estimate emissions, and through the development of
updated drilling rig engine emission profiles. The improved well activity data was obtained
through acquisition of the "Drilling Permit Master and Trailer" database from the Texas Railroad
Commission (TRC), while the improved drilling rig emissions characterization profiles were
obtained through a survey of oi l and gas exploration and production companies. The activity data
and emissions characterization data were then used to develop the drilling rig engine emissions
inventory for a 2008 base year.
In order to survey drilling rig contractors and oil and gas operators across the state, ERG
purchased contact information for companies that were active in well drilling activities that
occurred in Texas in 2008 through a commercial vendor (RigData®). Through phone and email
surveys , ERG obtained 45 drilling rig profiles representative of over 1,500 wells drilled in Texas
in 2008.
The survey effort itself foc u sed on collecting the following information from each
respondent:
• The number of engines on a rig
• Engine make, model , model year, and size (hp)
• Average load for each engine
1-1
• Engine function (draw works, mud pumps, power)
• Actual engine hour data for each well (total hours)
• Actual engine fuel use data for each well (total fuel use)
• Total well drilling time (actual number of drilling days)
• Total well completion time (number of days needed for well completion activities)
• Well depth
• Number of wells represented by survey
Target pollutants for this inventory include nitrogen oxides (NO x), volatile organic
compounds (VOC), carbon monoxide (CO), particulate matter (PM 10 and PM2.5), sulfur dioxide
(S02), and hazardous air pollutants (HAP). Emissions were calculated for each county in Texas
where drilling occurred in 2008 and are provided in annual tons per year and by typical ozone
season day . For planning purposes , the 2008 base year estimates were used to develop 2002 and
2005 prior year inventories , a s well as projected inventories for 2009 through 2021. 2002 and
2005 prior year inventories were based on TRC records of oil and gas well completions during
those years, and U.S Department of Energy (DOE), Energy Information Administration (EIA) oil
and gas production growth estimates were used to develop the projections for future years 2009
through 2021 .
Emissions estimates developed from this inventory project may be used for improved
input data to photochemical air quality dispersion modeling, emissions sensitivity analyses , State
Implementation Plan (SIP) development, and other agency activ ities . The final 2002 , 2005 , and
2008 base year inventory estimates are provided in National Emissions Inventory (NEI) Input
Format (NIF) 3.0 to facilitate entry of the data into the state's TexAER (Texas Air ,Emis sions
Repository) database , and for the purposes of submittal to US EPA. For purposes of NIF
preparation, Source Classification Code (SCC) 23-10-000-220 (Industrial Processes -Oil and
Gas Exploration and Production -All Processes -Drill Rigs) was used as provided by TCEQ
(TCEQ , 2009).
Table 1-1 summarizes the statewide annual emission estimates for 2002 , 2005 , and 2008
through 2021.
Table 1. 1 Drilling Rig Estimates (tons/year)
Year co NOx PMio PM2.s S02 voe
2002 13,305 35 ,828 2 ,552 2,475 4 ,776 3,631
2005 15 ,8 78 42 ,854 3 ,036 2,945 5 ,977 4 ,337
2008 16 ,721 55 ,238 2,543 2,467 956 4 ,326
2009 16 ,769 55,457 2 ,550 2,474 961 4 ,340
2010 16 ,336 53 ,123 2 ,417 2,344 45 4,182
1-2
Table 1.1 Drilling Rig Estimates {tons/year) {Continued) Year co NOx PMio PM2.s S02 voe 2011 15,117 48,462 2,319 2,249 44 3,806 2012 14,748 46,253 2,263 2,196 43 3,665 2013 12,008 39,793 1,378 1,337 38 3,413 2014 11,945 39,461 1,372 1,331 38 3,392 2015 11,755 38,837 1,350 1,310 37 3,349 2016 11,558 36,440 1,320 1,280 37 3,320 2017 8,915 34,771 1,118 1,085 36 2,800 2018 6,114 31,282 811 787 35 2,227 2019 6,073 31,127 805 781 35 2,215 2020 6,035 30,771 800 776 35 2,205 2021 3,299 26,063 448 435 33 1,504 1-3
2.0 Introduction
The purpose of this study was to develop a comprehensive emissions inventory for
drilling rig engines associated with onshore oil and gas exploration activities occurring in Texas
in 2008. Oil and gas exploration and production facilities are considered some of the largest
sources of area source emissions in certain geographical areas , dictating the need for continuing
studies and surveys to more accurately depict these activities. A previous study conducted by
Eastern Research Group (ERG) in 2007 under TCEQ contract 582-7-84003 , Work Order 01 was
comprehensive in coverage of all the exploration and production facility and equipment types,
including drilling rig engines, although this project relied on data from secondary sources with
assumptions applied to represent local activities (TCEQ , 2007). The Western Air Regional
Partnership (WRAP) developed a comprehensive emissions inventory of oil and gas exploration
and production facilities for the western states that did not include Texas, although the previous
ERG study did make use of the WRAP study in terms of methodology and emission factors
where practicable .
While drilling activities are generally short-term in duration, typically covering a few
weeks to a few months , the associated diesel engines are usu a lly very large , from several
hundred to over a thousand horsepower. As such, drilling activities can generate a substantial
amount ofNOx emissions. While previous studies have focused more intently on quantifying the
ongoing fugitive VOC emissions associated with oil and gas production, significant uncertainty
remains regarding the shorter term NOx emission levels associated with drilling activity.
In order to gain a more accurate understanding of emissions from drilling rig engines ,
data regarding typical rig profiles (number of engines , engine sizes, and engine load factors)
were collected through phone and email surveys for drilling operations for the 2008 base year.
These data were used to develop well drilling emissions profiles using US EPA's NONROAD
emissions model. 1 To develop the statewide emissions inventory, the drilling rig emissions
profiles developed as a result of the survey were applied to well drilling activity data for 2008
obtained from the Texas Railroad Commission (TRC).
The activity and drilling rig engine emissions profiles developed under this study were
used to develop emissions estimates of volatile organic compounds (VOC), nitrogen oxide
(NOx), carbon monoxide (CO), particulate matter (PM ,o and PM2.s ), sulfur dioxide (S02), and
1 While the NON ROAD model was used to calculate drilling activity emi ss ion s (in order to more accurate ly capture
emis sion standard phase in impacts), the se emissions are actually class ified as area sources emiss ions and reported
as s uch to th e TCEQ .
2-1
hazardous air pollutants (HAP) for drilling rig engines across the state. Emissions are calculated
on a county-level basis and provided in annual tons per year and by typical ozone season day.
For planning purposes , the 2008 base year estimates were used to develop 2002 and 2005 prior
year inventories, as well as projected inventories for 2009 through 2021.
Section 3.0 of this report provides the results of a review of existing literature as well as
currently available data that could be used to develop the inventory. This discussion also
provides an overview of the drilling process and identifies the types of activities and equipment
that are commonly associated with drilling activity. Section 4.0 provides an overview of the data
collection plan and the subsequent survey that was used to obtain the information needed to
develop the model drilling rig emissions profiles. Section 5.0 presents the results of the survey,
including a discussion of how the data was broken down into distinct "model" drilling rigs by
well type and depth. Section 6.0 describes the development of the emissions inventory including
how the activity data was compiled, how the model drilling rig emission profiles were
developed , and how these model drilling rig emission profiles were combined with the activity
data to develop the 2002 , 2005 , and 2008 through 2021 emission inventories.
2-2
3 .0 Review of Existing Literature
At the start of this study ERG conducted a review of re levant literature, current studies,
and avai lable data that cou ld be used in the deve lopment of a drilling rig engine emissions
inventory for Texas . The results of this research are discussed below in Sections 3 .1 through 3 .3.
Section 3 .1 discusses the review of existing studies concerning estimating emissions from oi l and
gas drill rig operations, Section 3 .2 covers the results of the review of existing Texas data
availab le from government and industry websites and publications , and Section 3.3 includes a
discussion of drilling rigs and the types of engines and activities occ urring during a drilling
operation.
3.1 Review of Existing Studies
Over the last several years numerous studies have been conducted in the western states to
deve lop area source emission estimates for oi l and gas exp loration and production sources , with
subsequent studies improving upon the data co ll ection methodology and emission estimation
approaches . Most of these studies addressed emissions from drilling rig engines to some degree .
The re levant studies ERG identified are listed in Table 3-1.
Table 3.1 Existing Oil and Gas Exploration Emissions Studies
R eport Title Geographic Publication Date
Covera2e
Oil and Gas Emission Inventories for the Western WRAP States December, 2005 States (Russell, et al., 2005)
Ozone Precursors Emission Inventory for San San Juan and
Rio Arriba Juan and Rio Arriba Counties , New Mexico Counties , August, 2006
(Pollack, et al., 2006) New Mexico
Emissions from Oil and Gas Production Facilities Texas August , 2007 (TCEQ, 2007)
WRAP Area Source Emissions Inventory
Projections a nd Contro l Strategy Evaluation WRAP States September, 2007
Phase II (Bar-Ilan, et al., 2007)
Development of Baseline 2006 Emissions from Denver-
Oi l and Gas Activity in the Denver-Julesburg Julesburg April , 2008
Basin (Bar-Ilan , et al., 2008) Basin,
Colorado
Recommendations for Improvements to the CENRAP CENRAP States' Oil and Gas Emissions States November, 2008
Invento ri es (Bar-Ilan, et a l., 2008a)
3-1
Table 3.1 Existing Oil and Gas Exploration Emissions Studies (Cont.)
Report Title Geographic Publication Date
Covera2e
Deve lopment of Baseline 2006 Emissions from Piceance
Oil and Gas Activity in the Piceance Basin (Bar-Basin, January, 2009
Ilan, et al., 2009) Colorado
Based on a review of these studies, ERG developed a series of survey questions to obtain
the types of data that would be needed to develop the 2008 base year emissions inventory . The
resultant survey was developed using example survey questions and forms from several of these
existing studies.
The studies identified in Table 3-1 were comprehensive in nature, inclusive of all
emission sources found at oil and gas exploration and production locations. While drilling rig
engines were typically included in these studies, this source category was not the primary focus
of these efforts, as these inventories addressed emissions sources associated with both the
exploration and production sides of the oil and gas industry. As such, many of the surveys used
in these studies were sent to the oil and gas producers themselves , and not directly to the owners
and operators of the drill rigs, who are typically contracted by the producers to drill the well. As
described below in Section 5 , ERG focused this survey effort on the drilling contractors
themselves, who are most familiar with drilling equipment and activities, with less emphasis on
the production companies.
3.2 Review of Existing Data
All exploratory oil and gas drilling in Texas requires a permit. These permits are
processed and maintained through the TRC. The drilling permits are available for review through
the TRC website, and include well-specific data such as approval date, location (county), well
profile (vertical, horizontal, directional), we ll depth, start or "spud-in" date , and well completion
date. On March 10, 2009, ERG obtained this data in electronic format through acquisition of the
"Drilling Permit Master and Trailer" database. This database formed the basis of the activity data
used to develop the 2008 base year emissions inventory.
In addition to the drilling permit data obtained through the TRC, many of the larger
drilling contractors provide information about their drilling rig fleets in their on-line websites.
Examples of these websites are provided in the approved Data Collection Plan, which is included
as Appendix A ofthis report. ERG reviewed this on-line information in an effort to gain a better
understanding of typical drilling rig engine profiles , including the size, number, and type of
3-2
engines used on typical rigs. Additional information provided included make and model of the
engines. Engine manufacturer websites were also reviewed and proved useful as a resource to
obtain engine specifications and fuel usage data that could be used to gapfill the data obtained
during the survey and needed to complete the emissions inventory. For example, engine fuel
usage data could be used to determine load percentages for engines where the operator provided
fuel use data but did not provide load estimates.
3.3 Drilling Rig Overview
Air pollutant emissions from oil and gas drilling operations originate from the
combustion of diesel fuel in the drilling rig engines. The main functions of the engines on an oil
and gas drilling rig are to provide power for hoisting pipe, circulating drilling fluid , and rotating
the drill pipe. Of these operations , hoisting and drilling fluid circulation require the most power.
There are two common types of rigs currently in use
-mechanical and electrical. In general , mechanical rigs
have three independent sets of engines. The first set of
engines ( draw works engines) are used to provide power to
the hoisting and rotating equipment, a second set of engines
(mud pump engines) are dedicated to circulating the drilling
fluid which is commonly referred to as "mud", and a third
Draw Works engines -
used to power hoisting and
rotating equipment
Mud Pump engines -used
to circulate drilling fluid
Generator engines -used to
power auxiliary equipment
set of engines (generator engines) are used to provide power to auxiliary equipment found on the
drill site such as lighting equipment and heating and air conditioning for crew quarters and office
space. There may be one , two , or more draw works engines , depending on the input power
required. There are typically two mud pumps for land rigs , with each mud pump independently
powered by a separate engine. The mud pump engines are typically the largest engines used on a
mechanical rig. Finally, there are typically two electric generator engines per mechanical rig,
with one running continuously and the second serving as a stand by unit.
Electrical rigs are typically comprised of two to three large, identical diesel-fired engine-
generator sets that provide electricity to a control house called a silicon controlled rectifier (SCR)
house. Electricity from the SCR house is then used to provide power to separate motors on the
rig . In this configuration, there are dedicated electric motors used for the draw works/hoisting
operations, the mud pumps , and other ancillary power needs (such as lighting). The generator
engines are loaded as required to meet fluctuating power demands, with one unit typically
designated for standby capacity. The trend in new rig design is almost exclusively towards
electric rigs, except perhaps for the smallest rigs . This is probably due to the relative expense of
3-3
engines versus motors, both in terms of initial cost and maintenance. Today, electrical rigs are
common , especially for larger rigs (Bommer, 2008).
After drilling and casing a well , it must be "completed." Completion is the process in
which the well is enabled to produce oil or gas . Once the desired well depth is reached, the
geological formation must be tested and evaluated to determine whether the well will be
completed for production, or plugged and abandoned. To complete the well production, casing is
installed and cemented and the main drilling rig is dismantled and moved to the next site . A
smaller rig , called a completion rig (also known as a workover rig), is then moved on site to
bring the well into production, to perforate the production casing and run production tubing to
complete the well. Typically, the completion rig is a carrier-mounted arrangement and may be
on-site for se veral days to a week or more depending on well depth and other factors . The
completion rigs hoist smaller loads and pump at lower rates than the drilling rigs , and therefore
require much smaller engine capacity.
Increasingly, reservoir productivity is enhanced by the application of a stimulation
technique called hydraulic fracturing . In this process , the reservoir rock is hydraulically
overloaded to the point of rock fracture. The fracture is induced to propagate away from the well
bore by pumping hydraulic fracturing fluid into the well bore under high pressure. The fracture is
kept open after the end of the job by the introduction of a solid proppant ( sand, ceramic , bauxite,
or other material), by eroding the sides of the fracture walls and creating rubble by high injection
rates, or for carbonate formations , by etching the walls with acid. The fracture thus created and
held open by the proppant materials becomes a high conductivity pathway to the well bore for
reservoir fluid.
In vertical wells a single fracture job per reservoir is commonly done . In high angle or
horizontal wells , it is common to perform multiple fracturing jobs (multi stage fracturing) along
the path of the bore hole through a reservoir. Fracturing jobs are often high rate , high volume,
and high pressure pumping operations. They are accomplished by bringing very large truck-
mounted diesel-powered pumps (e.g., 2,000 hp or more) to the well site to inject the fracturing
fluids and material, and to power the support equipment such as fluid blenders. The measure of
the power required is based on the hydraulic horsepower necessary to fracture the well. Although
very short in duration (typically less than a day), fracturing activities may result in substantial
NOx emissions due to the very high horsepower requirements.
Oil and gas wells are commonly classified as vertical, directional , or horizontal wells ,
depending on the direction of the well bore. Vertical wells are the most common, and are wells
3-4
that are drilled straight down from the location of the drill rig on the surface. Directional wells
are wells where the well bore has not been drilled straight down , but has been made to deviate
from the vertical. Directional wells are drilled through the use of special tools or techniques to
ensure that the well bore path hits a particular subsurface target, typically located away from (as
opposed to directly under) the surface location of the well. Horizontal wells are a subset of
directional wells in that they are not drilled straight down, but are distinguished from directional
wells in that they typically have well bores that deviate from vertical by 80 -90 degrees.
Horizontal wells are commonly drilled in shale formations . Once the desired depth has been
reached (the well bore has penetrated the target formation), lateral legs are drilled to provide a
greater length of well bore in the reservoir.
3-5
4.0 Data Collection Plan
ERG's Data Collection Plan identified the proposed approach for collecting the
information needed to develop a comprehensive emissions inventory for land-based drilling rig
engines in the state of Texas in 2008 . The primary focus of the data collection survey was to
obtain engine operating data from rig operators who were actively drilling in Texas in 2008. The
goal of this survey was to obtain sufficient data to allow for the development of a series of
"model" drilling rig emission profiles for different well types and/or depths to apply to the
corresponding subsets of the TRC well activity data.
Details of the Data Collection Plan were subject to external peer review and approved by
TCEQ . ERG conducted the data collection as per the approved Data Collection Plan, which is
included as Appendix A.
4.1 Participant Recruitment
In order to encourage survey response rates, stakeholder support for the study was
sought. In addition to consulting with contacts at the University of Texas, Southern Methodist
University, and the Texas Railroad Commission for suggestions on implementing the survey and
soliciting participants, the following trade associations were contacted to help encourage
participation in the study:
• International Association of Drilling Contractors (IADC)
• Texas Independent Producers and Royalty Owners Association (TIPRO)
• Texas Oil and Gas Association (TXOGA)
ERG provided the trade associations with a draft copy of the survey materials and
requested they distribute them to their membership for feedback. In addition, ERG requested
these trade groups lend their support to the project through a letter of introduction ab out the
study to be sent to their constituents. While these associations were supportive of the goals and
appreciated the need for this study, ERG did not receive any feedback on the draft survey
materials. However, both TIPRO and TXOGA recognized the importance of the project and
agreed to allow ERG to reference their support in the survey transmittal letter (see Appendix B).
4.2 Phone/Ema il Surveys
Once the survey was developed, ERG obtained contact information for oil and gas well
operators and drilling contractors in order to distribute the survey. The primary source of data
used to identify target respondents was the commercial RigData® database. This database
4-1
contains information for over 24 ,000 drilling permits issued inTexas between January 1, 2008
and March of 2009. For over 14 ,000 of these records, drilling contractor contact information was
provided. The RigData® database used to develop the target respondent list has been provided to
the TCEQ in electronic format
ERG attempted to contact each of the drilling contractors included in this listing through
phone and/or email surveys. The survey effort itself focused on collecting the following
information from each respondent:
• The number of engines on a rig
• Engine make , model , model year, and size (hp)
• Average load for each engine
• Engine function (draw works , mud pumps , power)
• Actual engine hour data for each well (total hours)
• Actual engine fuel use data for each well (total fuel use)
• Total well drilling time (actual number of drilling days)
• Total well completion time (number of days needed for well completion activities)
• Well depth
• Number of wells represented by survey
An example of the data collection form used to compile the results of the survey is
presented in Appendix C. For those respondents who were contacted via email , an Excel file
containing similar information was provided as an email transmittal. The results of the survey
effort are described in Section 5.0.
4.3 Confidentiality
Confidentiality was stressed to survey participants, as evidenced in the survey letter. ERG
is particularly sensitive to the privacy of individuals and businesses . Therefore all interviews and
data collection efforts began with a guarantee of privacy, anonymity, and confidentiality . To
ensure survey respondent's rights to privacy, respondents were informed of the research purpose,
the kinds of questions that would be asked, and how the TCEQ may use the results of the study.
Confidentiality was maintained by eliminating respondent names from the study datasets before
provision to the TCEQ .
4-2
5.0 Data Collection Results
5.1 Survey Findings
Using the contact information in the RigData® dataset, ERG began implementation of the
Data Collection Plan on April 30, 2009 and collected data through June 16 , 2009. Initially ,
contacts were attempted with many of the oil and gas well operators themselves . As a rule, the
operators were knowledgeable concerning general information about the drilling process
including average depth , drilling days, number of engines used and gallons of fuel used per day.
However, they typically did not have the specific information about the characteristics of the rig
engines (model year, engine size , and load factors) needed to estimate emi ssions.
During phone interviews it was discovered that several of the operators also drilled their
own wells . Based on these interviews , the strategy for the remainder of the data collection phase
of the project was refined . In particular, factors such as depth of the well , the engine
configurations used , the individual preferences of drilling superintendents to idle engines or to
tum them off, and the difficulty of estimating load and operating hours over the entire drilling
period made it difficult to collect the data via email or fax without being able to discuss the
needed data directly with the respondent. The complexity of the drilling process and the lack of
response from the operators to anything other than a verbal interview informed the collection
process for the drilling contractors.
Therefore to obtain the information needed, a verbal interview with the actual drilling
contractors was determined to be preferable in order to carefully walk the respondent through the
survey questions.
The RigData® dataset included approximately 225 unique contact profiles for drilling
contractors . However, many of these contacts were regional contacts for the same company,
several had gone out of business , and others had recently consolidated into a single company . As
a result , the final number of unique contacts for the drillers was approximately 190 .
ERG attempted to contact each of the drilling companies at least four times, by phone
and/or email. Based on the experience with contacting the operators , verbal contact was
attempted with each respondent before distribution of the survey through email or fax . The
strategy was designed to increase participation by explaining the purpose of the survey, to
explain the data being requested , and thus avoid receiving incomplete or inaccurate surveys . For
each targeted survey respondent , three attempts were made via phone to find someone to speak
5-1
with before a voicemail was left or an email was sent. This strategy was intended to eliminate
dead-end contacts such as unreturned voicemails or emails .
Because smaller companies generally had fewer administrative and management
personnel, contact for companies with less than 50 wells generally consisted of a phone call
answered by a receptionist who either took a message, transferred the call to a voicemail, or
established direct contact with someone who could answer the survey questions . If there was no
answer, a return call was scheduled. After three attempts without response , a short voice message
was left . If no reply was received to this message, no further attempt was made to contact the
respondent.
For the larger drilling companies (those that drilled over 100 wells in 2008), an enhanced
contact strategy was used . Because some of the companies are quite large and represent a
significant percentage of the wells drilled in the state, more extensive efforts were made to
increase their participation . For several of these companies , an effort was made to encourage
response by providing them with tailored Excel spreadsheets identifying their wells and asking
about specific well types and locations. In addition, attempts were made to contact the company
through multiple avenues, either through multiple contacts provided in the RigData® dataset , or
through contact information available on-line. In one case, ERG collected data from one of the
top 25 drilling contractors after an initial refusal from one drilling superintendent by requesting
data through other contacts at the company.
Generally speaking, at least ten contacts through phone calls and emails were attempted
for the larger companies, the medium sized companies required from 5 to 7 contacts, and the
smaller companies required 3 to 4 contacts before identifying the appropriate person to talk to.
At the completion of the survey effort, 45 completed surveys with sufficient data to
estimate emissions had been obtained from 39 different drilling rig contractors and/or oil and gas
well operators. This figure reflects approximately a 15% response rate for complete surveys from
the attempted contacts. One additional survey was received after the submittal cutoff date , but it
was not received in time for incorporation into the inventory.
The surveys that were received and used in the inventory were representative of over
1,500 wells drilled in Texas in 2008 and covered 121 counties and all of the major oil and gas
basins in the state (Andarko, East Texas, Ft. Worth/Bend Arch, Permian, and Western Gulf). An
additional 17 survey responses were obtained, but the respondents for these surveys did not
provide sufficient information to be used in the final model drilling rig emission profile
development. Typically, these incomplete responses were those received from the oil and gas
5-2
well operators and not the drilling contractors. Considering both the complete and incomplete
survey responses , the overall response rate for the survey effort was approximately 21 %.
Table 5-1 presents the summary results for the survey effort.
Table 5.1 Survey Summary Statistics
Survey Activity/Results Number of Respondents
Attempted Company Contacts 295
Refusal to Participate 24
Soft Refusal ( did not return attempted contacts via
phone calls or email) 209
Respondent Interviewed and provided sufficient data
for inclusion in inventory dataset 45
Respondent Interviewed, but insufficient data
provided for inclusion in inventory dataset 17
Figure 5-1 provides a county-level map of Texas providing a graphical representation of
the geographic coverage of the survey results .
5.2 Model Rig Category Development
Upon completion of the survey and data collection task, the survey results were compiled
into a spreadsheet database for evaluation in order to disaggregate the survey data into sub-
categories for model drilling rig profile development. As each completed survey was received
from the surveyor, identifying information for that survey was entered into a tracking
spreadsheet, and the survey was prepared for data entry and forwarded to data entry personnel.
Upon receipt of the survey, data entry personnel transferred the data in the survey form into the
spreadsheet database, and updated the survey tracking spreadsheet with date of data entry and
their initials. A QA check was then performed on the data entered into the spreadsheet database ,
and the tracking spreadsheet was updated to indicate the date of QA and the initials of the
personnel performing the QA.
5-3
Figure 5.1 Counties with Survey Data
Survey results for vertic a l, directional , and horizontal well types were reviewed as
described below.
A review of the 32 surveys completed for vertical drilling, representing 1,261 wells ,
pro v ided a clear distinction between the engine profiles (number and size of engines) used to
drill shallow vertical wells relative to deeper vertical wells. In particular, by separating the
5-4
survey results into those representing wells at 7,000 feet of depth or less , and those representing
wells deeper than 7,000 feet , the following differences were observed:
• The average drilling duration for the shallower wells was 8 days , with a maximum of
14 days;
• The average drilling duration for deeper wells was 27 days , with a maximum of
84 days ;
• Only 1 of the 16 profiles for shallow wells was for an electrical rig, compared to
6 electrical rig profiles out of the 16 profiles for the deeper wells;
• The engine sizes were significantly different for the shallow and deep wells , with the
survey results for the shallow wells containing no engines over 700 hp, while the
engine population for surveys received for the deeper wells contained approximately
25 engines rated at over 1,000 hp .
For horizontal and directional wells , a total of 13 completed surveys were recei ved
representative of 288 wells. The average measured well depth of the wells covered under these
surveys was approximately 11 ,000 feet , with a minimum of 8 ,000 feet and a maximum of
17 ,688 feet. All of the profiles for horizontal and directional wells were either for e lectrical rigs
(6 profiles) with 2 or 3 engines, or for mechanical rigs (7 profiles) with 6 engines . Due to the
limited number of surveys received for horizontal and directional wells , and the relative
consistency of the profiles for the se types of wells , it was determined to consolidate the survey
results for horizontal and directional wells into one model rig category .
Table 5-2 provides a summary of the final survey statistics for each of the three model rig
well type categories .
Table 5.2 Model Rig Category Statistics
Number Number of
Model Rig of surveys respondents Number of Number of Number of
Well Type included providing Wells Mechanical Electrical
Cate2ory in profile surveys Represented Ri2 Profiles Ri2 Profiles
Horizontal and
Directional 13 10 288 7 6
Wells
Vertica l W e lls 16 16 900 15 1 <= 7,000 feet
Vertical Wells > 16 13 361 10 6 7 ,000 fee t
Tables D-1 through D-3 in Appendix D contain the collected survey data for each of the
three model rig well type categories .
5-5
5.3 Fracturing
During the data collection phase of this project, information was solicited from
respondents regarding fracturing activities . While not specifically mentioned in the original work
plan or data collection plan, a review of existing literature and studies showed fracturing acti v ity
to be increasing in Texas over the past several years. As part of their survey response , the drilling
contractors and oil and gas exploration companies occasionally provided some qualitative or
quantitative information regarding fracturing , but the responses were highly variable in content
and format. In general , the indication was that fracturing was a short-term activity (less than one
day in duration), and that pump trucks containing multiple, large diesel-fired engines could be
used simultaneously to pump the fracturing fluids into the well. Specific information regarding
the frequency of fracturing events and the total hp-hours required per event were not
generalizable to the inventory as a whole, however.
Further investigation regarding fracturing was made by contacting service companies that
prov ide fracturing services , as well as interviewing personnel at the TRC and researching the
availability of fracturing data on-line through the TRC website.
Two of the three service companies contacted provided some data for the fracturing
activities they performed in 2008 , which varied from the use of five 1,250 hp pump engines for a
total duration of 1 hour, to the use of seven 2,500 hp pump engines for a total duration of
12 hours . The third service company contacted did not provide any data as of the time of this
draft report.
Unlike the drilling permit records obtained through the "Drilling Permit Master and
Trailer" database , fracturing data is not compiled by the TRC or otherwise made readily
available in any summarized format through any on-line queries or electronic datasets. However,
images of individual well completion records (referred to as G-1 forms for gas well completions
and W-2 forms for oil well completions) are available on-line through the TRC website. Using
American Petroleum Institute (API) numbers from the TRC data, a random on-line search was
performed to review the G-1 and W-2 records for approximately 1,200 wells. The G-1 and W-2
forms were only found for approximately one-third of these wells. These forms are frequently
completed by hand, with inconsistent data being reported by individual well operators , with
much of the data being incomplete. However, based on a review of the records we were able to
identify, it appears that approximately 80 % of the wells in the sample had some kind of
fracturing activity occurring prior to well completion.
5-6
While data is not currently available under this project to provide emission estimates for
fracturing activities, due to the large engine sizes used by the pump trucks , this is a source
category that may be considered for inclusion in future emission inventory development projects .
5-7
6.0 Emissions Inventory Development and Results
The 2008 activity data from the TRC and the model rig emissions profiles developed
using the survey results for each model rig well type category were utilized to develop emissions
estimates for selected target years as described below.
6.1 Activity Data
6.1.1 2008 Base Year Activity
Activity data for the 2008 base year was obtained from the TRC through acquisition of
the "Drilling Permit Master and Trailer" database, which contains information on well drilling
activities , including American Petroleum Institute (API) number, date approved, location
(county), well profile (vertical , horizontal , directional), well depth, spud-in date , and well
completion date. The TRC data was combined with data from the RigData® dataset used to
identify survey respondents as discussed previously. This combined database was used to
compile an initial list of all oil and gas wells that were either completed in 2008 (based on
completion date), or that were started in 2008 (based on spud-in date).
As many of the wells completed in 2008 were started in 2007 , and many of the well s
started in 2008 were not completed until 2009 , an adjustment was needed to the initial list of
wells to determine a representative dataset for 2008. This adjustment was accomplished by
including only those wells with spud dates of December 1, 2007 or later ( and that were
completed in 2008), and only those wells with completion dates of January 31, 2009 or earlier
(and that had spud-in dates in 2008). In all, 16,964 oil and gas wells are included in the final
2008 dataset which compares favorably with the 16,569 oil and gas well completions reported by
the TRC in 2008 (TRC , 2009c). The slight discrepancy with the total wells included in the 2008
dataset compared to the completion figure from the TRC is due to the fact that the TRC data only
includes 2008 completions and does not account for wells started in 2008 that were not
completed until 2009.
The final 2008 activity dataset contains drilling activity data for 210 of the 254 counties
in Texas.
6.1.2 2002 and 2005 Prior Years Activity
Once the final 2008 activity dataset was established, activity data scaling factors for 2002
and 2005 were developed based on the ratio of the oil and gas well completions for those years
relative to the number of oil and gas well completions in 2008 as reported by the TRC (TRC
6-1
2009a, TRC 2009b, TRC 2009c ). This analysis was performed at the TRC district level, which
allowed geographic variation in drilling trends across the state from 2002 through 2008 to be
reflected in the 2002 and 2005 prior year datasets. Figure 6-1 provides a county-level map of
Texas showing the location and coverage of each of the TRC districts .
Oil and Gas Division
District Boundaries
District Office
1 &2 San Antoni o
3 Hous ton
4 Corpus Christi
5&6 Kilgore 8 78 Abi lene
7C San Angelo
8&8A Midland RAI LROA.D COMM lSS ION ofTEXAS
9 Wich ita F a!l s Oil Md G311 l)fvision
10 Pampa
Figure 6.1 TRC District Map
6-2
For example, in 2008 there were 512 total oil/gas well completions in TRC District 1, and
in 2002 there were 165 total oil/gas well completions in District 1. Therefore , the scaling factor
from 2002 to 2008 is:
2002 to 2008 scaling factor= 165 wells / 512 wells = 0.32
Table 6-1 shows the 2002 , 2005 , and 2008 oil and gas well completion records and the
resultant 2002 and 2005 scaling factors that were developed for each district for this analysis.
Table 6.1 2002 and 2005 Prior Year Activity Scaling Factors
2008 Total 2002 Total 2005 Total
Oil/Gas Oil/Gas 2002 Scaling Oil/Gas 2005 Scaling
TRC District Completions Completions Factor Completions Factor
1 512 165 0 .32 389 0 .76
2 687 513 0.75 672 0 .98
3 699 724 1.04 712 1.02
4 1,351 1,266 0.94 1,123 0 .83
5 738 61 8 0.84 714 0 .97
6 1,973 717 0.36 1,556 0.79
7B 746 298 0.40 501 0 .67
7C 2 ,082 88 7 0.43 1,389 0.67
8 2 ,641 1,281 0.49 927 0 .35
8A 559 756 1.35 626 1.12
9 3,484 1,096 0.31 1,185 0 .34
10 1,095 419 0.38 856 0 .78
As can be seen in Table 6-1 , certain areas of the state experienced significant growth in
drilling activity in 2008 relative to 2002, while other areas remained relatively stable. The most
dramatic ex ample of this change in activ ity can be seen in TRC District 9 , which contains the
Barnett Shale, an area that has experienced significant growth in drilling activ ity over the last
6 years. For this District, drilling activity approximately tripled between 2002 and 2008 .
The scaling factors presented in Table 6-1 were applied to the 2008 base year well depth
totals by county for each of the three model rig well types to determine county-level well depth
for each model rig type for 2002 and 2005.
6.1.3 2009 through 2021 Projected Activity
2009 through 2021 projected activity data were developed using the 2008 base year
activity data from the TRC and forecasting future activity based on US DOE Energy Information
Administration (EIA) projections of oil and gas production for the Southwest and Gulf Coast
6-3
regions from the A nnual Energy Outlook 2 009, Updated R ef erence Cas e with ARRA (EIA,
2009). The EIA data tables (specifically Tables 113 and 114) present estimated crude oil and
natural gas production estimates for the years 2006-2030 . The geographic level of the projected
data is by EIA Region .
Portions of Texas fall into three EIA Regions: Gulf Coast (Region 2); Southwest (Region
4); and Midcontinent (Region 3). The majority of the State is in the Gulf Coast and Southwest
EIA Regions . Only a small portion (area to the west of Oklahoma) is in the Midcontinent
Region. In addition, because the Midcontinent EIA Region contains six other states, any
projections data for the Midcontinent EIA Region may not be reflective of Texas operations .
Thus, it was assumed that the Southwest and Gulf Coast EIA Regions are representative of Texas
and each region was weighted equally to determine the statewide projections. Figure 6-2 shows
the EIA regions and their coverage in Texas.
Figure 6.2 EIA Reg ions
Tables 6-2 and 6-3 show projected crude oil and natural gas production for the Gulf
Coast and Southwest EIA Regions, as well as the combined total for both regions , from 2008
through 2021 . The total percentage change for each y ear from 2009 through 2021 is presented
relative to the base year of 2008.
This data was then used to calculate a projected growth factor(%) for each year from
2009 through 2021 by weighing the oil and gas percentage growth figures relative to the number
of oil and gas we lls completed in Texas 2008. For example, the projected growth factor for 2009
is calculated as follows:
6-4
Table 6.2 Projected Crude Oil Production 2008-2021
Crude Oil Production (MMBBL/dav)
EIA Region 2008 2009 2010 2011 2012 2103 2014 2015 2016 2017 2018 2019 2020 2021
Gulf Coast 0 .503 0 .505 0.503 0.483 0.465 0.450 0.438 0.401 0 .374 0.347 0.320 0.294 0.271 0 .251
Southwest 0 .919 0.920 0.904 0 .8 92 0.890 0.915 0 .956 1.000 1.043 1.082 1.117 1.147 1.167 1.183
Total 1.422 1.425 1.407 1.375 1.355 1.365 1.393 1.402 1.416 1.429 1.436 1.442 1.438 1.434
% change from 2008 0.21 % -1 .05% -3 .29% -4 .7 1% -4.01% -2.02% -1.42 % -0.39% 0.50% 1.02% 1.38 % 1.14 % 0 .86%
Table 6.3 Projected Natural Gas Production 2008-2021
Natural Gas Production (trillion cubic feet)
EIARegion 2008 2009 2010 201l 2012 2103 2014 2015 2016 2017 2018 2019 2020 2021
Gulf Coast 5.412 5.165 4 .792 4.606 4.415 4.326 4 .233 4.162 4.086 4.020 3.959 3.921 3 .903 3.825
Southwest 2.170 2.474 2 .623 2 .716 2.713 2.679 2.659 2.645 2.627 2.609 2 .603 2.591 2.591 2 .564
Total 7.582 7.639 7.415 7.321 7.128 7.005 6.892 6 .807 6.713 6.629 6.563 6.512 6.495 6.388
% change from 2008 0.76% -2.20% -3.44 % -5 .99% -7 .61% -9.09% -10 .2% -11.5 % -12.6% -13.4 % -14 .1% -14.3 % -15 .7%
6-5
2009 growth factor =((%change from 2008 to 2009 in Crude Oil Production x number of oil
well completions in 2008) +(%change from 2008 to 2009 in Natural Gas
Production x number of gas well completions in 2008)) / (total number of
oil and gas well completions in 2008)
Using the data in Tables 6-2 through 6-4, the projected growth factor for 2009 is:
2009 growth factor = ((0.21 % x 6 ,208) + (0.76% x 10 ,361)) / (6 ,208 + 10 ,361) = 0.55 %
Table 6-4 shows the growth factors that were developed for each projected year as a
result of this analysis . These factors were then applied to the 2008 base year well depth totals by
county for each of the three model rig profile well types to determine activity data for 2009
through 2021 . It is worth noting that through the first five months of 2009, the number of well
completions in Texas has exceeded the number of well completions for the same period in 2008.
However, during the second half of 2008 , there was a dramatic increase in drilling activity in
Texas which dropped off significantly by the end of the year due to commodity prices and the
effects of the economic recession. Therefore , while Table 6-4 presents projected production data
based on the current DOE EIA data, the volatility in drilling activity during 2008, coupled with
the rapidly changing economic climate over the last year, results in a high level of uncertainty
regarding these ( or any) projections for drilling activity in 2009 and beyond. These projections
are based on the best data currently available , but should be revisited once the economic climate
and oil and gas prices stabilize in order to more accurately assess future year projected
ermss10ns .
6.1.4 2002, 2005, and 2008 through 2021 Activity Summary
Once the final activity dataset for 2008 was determined, total county-level well depth for
each of the three model rig well type categories was calculated by summing the individual well
depths in each county by model rig well type category. The total county-level well depth for
2002, 2005 , and 2009 through 2021 for each model rig well type category was then calculated
based on the 2008 summary data using the methodology described above. Table 6-5 shows the
total depth by model rig well type category for 2008 (blank cells indicate there was no activity in
that county for that well type).
6-6
Table 6-4 Projected Growth Factors 2009-2021
Production % chane:e from 2008
2008 Well Completions 2009 2010 2011 2012 2103 2014 2015 2016 2017 2018 2019 2020 2021
Oil I 6,20 8 0 .2 1% -1 .05 % -3 .29 % -4 .71 % -4 .01 % -2.02% -1.42 % -0 .39% 0 .50% 1.02 % 1.38% 1.14% 0 .8 6%
Natural Gas I 10 ,361 0 .76% -2 .20% -3.44% -5 .99% -7 .61 % -9 .09 % -10.2 % -11.5 % -12 .6% -13.4% -14 .1% -14 .3% -15 .7%
Projected Gro w th Factor 0 .55 % -1.77 % -3 .38 % -5 .51 % -6 .2 6% -6.44 % -6 .92 % -7.31 % -7 .67 % -8 .02% -8 .31 % -8 .54 % -9 .52 %
6-7
Table 6.5 2008 Total Depth by Model Rig Well Type Category (1,000 feet)
County Vertical <= 7,000 feet Vertical > 7,000 feet Directional/Horizontal
Anderson 52 .20 113 .70 20.33
Andrews 1,969.19 1,115.41 46 .30
Angelina 1.32 394 .74 101.70
Aransas 6 .00 45.45 23.30
Archer 221.32 15.50
Atascosa 39 .80 38.50
Austin 67.19 28.70 15 .02
Bastrop 6.40 74 .60 71.70
Baylor 45 .54 5.50
Bee 239.20 204.49 240 .25
Bell 4 .50
Bexar 0.80
Borden 11.45 166 .10 42.85
Bosque 10.00 15 .80
Bowie 9.00
Brazoria 15.90 252.90 103.39
Brazos 33 .14 214 .89
Briscoe 6 .50 8 .50
Brooks 17.16 582 .32 103.96
Brown 41.00
Burleson 208.41 172 .77
Caldwell 29 .86 8.15
Calhoun 15.60 112.60 82 .83
Callahan 81.68
Cameron 9 .50
Carson 6.50 10.10
Cass 7 .00
Chambers 78 .60 153.46
Cherokee 9.40 886 .08 243.05
Childress 9.30
Clay 116 .15 23.00 52.50
Cochran 229 .30 25.00
Coke 121.70 15.70
Coleman 97 .69
Colorado 122. 71 149.88 25.42
Comanche 3.00
Concho 167.15
Cooke 161.00 228 .84 17 .90
Coryell 4.00
Cottle 39.20 106.70 8 .00
Crane 602.54 175 .75 43.26
Crockett 881.48 1,822.74 131.17
Crosby 91.69
Culberson 216 .89 44 .00
Dallas 99.50
6-8
Table 6.5 2008 Total Depth by Model Rig Well Type Category (1,000 feet) (Cont.)
County Vertical <= 7,000 feet Vertical> 7,000 feet Directional/Horizontal
Dawson 42 .70 359 .69 17.50
Denton 11.10 79 .50 2,491.72
DeWitt 57.40 392.08 568 .84
Dickens 174.02 123.70
Dimmit 270.51 178.14 125 .64
Duval 68.80 479.83 71.95
Eastland 48.09
Ector 501.36 1,619.73 73.30
Edwards 119 .55 206.10 67 .50
Ellis 1.50 269 .00
Erath 29.95 97.10
Falls 1.80
Fannin 19 .00
Fayette 15.08 22.10 93 .80
Fisher 162 .58 68.30
Foard 25 .10
Fort Bend 159 .90 74.65 125 .04
Franklin 10.90 94 .55
Freestone 11.40 2,650.39 484 .37
Frio 153 .73 62 .80 61.74
Gaines 407.24 633 .81 56 .99
Galveston 4.40 51.15 53 .37
Garza 189 .30 52 .00 3 .20
Glasscock 900 .20 19 .20
Goliad 231.61 377.49 76.04
Gonzales 15.53 21 .26 21.50
Gray 12 .15 13 .00
Grayson 12.99 49 .00 37 .60
Gregg 503.10 263 .25
Grimes 3 .90 169.64
Guadalupe 9 .20 7 .79
Hale 65 .00 15 .00
Hansford 62.41 263 .33 50.20
Hardeman 12.59 96 .23 28.60
Hardin 81.95 284.12 180.35
Harris 19 .20 34 .20 85.40
Harrison 60 .61 2,900.41 1,836.28
Hartley 17 .95
Haskell 63 .70
Hemphill 6.50 3,936.45 685.47
Henderson 233 .25 53.60
Hidalgo 37.54 1,324 .96 347 .92
Hill 7 .00 1,161.12
Hockley 208.43 123.40 87.44
Hood 1,011.19
6-9
Table 6.5 2008 Total Depth by Model Rig Well Type Category (1,000 feet) (Cont.)
County Vertical <= 7 .000 feet Vertical> 7.000 feet Directional/Horizontal
Hopkins 4.50 21.80
Houston 8.30 161.85 56 .50
Howard 81.64 779 .85
Hudspeth 26.00 22 .00
Hutchinson 313 .77 17 .10 39 .00
Irion 196.70 1,513.07
Jack 197.69 137 .50
Jackson 205.63 319 .66 32 .99
Jasper 8.10 44.50 194.33
Jefferson 24.80 166 .30 300.61
Jim Hoi:rn: 9.40 194 .13 14.38
Jim Wells 84.07 52.75 6.11
Johnson 52 .00 8,421.16
Jones 221.93
Karnes 21.40 100.90 179 .60
Kenedy 7.00 382.44 92.50
Kent 120.99 109 .80 36.00
King 203.90 7.40
Kleberg 54.50 150.10
Knox 54.20 7 .20
La Salle 52.36 691.44 24 .00
Lamb 32.80 7 .50
Lavaca 107 .69 552.74 216.53
Lee 35.30 24.48 83.01
Leon 68.91 524 .00 310.50
Liberty 34.00 330 .85 145.10
Limestone 6.30 1,876 .14 451.40
Lipscomb 214 .88 1,447.13
Live Oak 132.03 342.83 129.60
Loving 149 .1 0 620.83 33 .00
Lubbock 60.30
Lynn 46 .25
Madison 36.31 66 .20
Marion 104.73 66 .50
Martin 3 ,643.04
Matagorda 25.97 590 .09 100.27
Maverick 333.88 27 .00 241.35
McCulloch 1.00
McLennan 1.23 9.50 9.50
McMullen 128 .79 749 .60 49.50
Medina 30.11
Menard 70.50
Midland 8.60 2 ,637.28 75.30
Milam 19 .2 9 10.00
Mitchell 640 .83
6-10
Table 6.5 2008 Total Depth by Model Rig Well Type Category (1,000 feet) (Cont.)
County Vertical <= 7,000 feet Vertical > 7,000 feet Directional/Horizontal
Montague 107 .08 475.44 365.20
Montgomery 6 .00 51.95 24 .52
Moore 126.48 6.30
Motley 5.00 9.00
Nacogdoches 1.00 2,210.41 761.92
Navarro 36.15 102 .10 6 .60
Newton 30 .55 68.50
Nolan 332 .89 37.70
Nueces 66 .84 339 .36 64 .62
Ochiltree 16.50 309 .88 427 .67
Oldham 45 .90
Orange 7 .00 17 .00 101.32
Palo Pinto 212 .17 135 .05
Panola 92 .08 2 ,693 .70 1,652.45
Parker 6.45 880 .85
Pecos 224.68 2,667.60 840 .55
Polk 60.63 90 .83 218 .65
Potter 21 .20
Reagan 34.05 2,509.42
Real 3 .00
Red River 5 .80 8.20 5 .80
Reeves 88 .15 310.70 374 .12
Refugio 588.28 335 .65
Roberts 17 .80 1,337 .30 361.71
Robertson 2,317 .69 438 .50
Runnels 375.57 4 .80
Rusk 27 .00 3 ,697.44 508.05
Sabine 8.00
San Augustine 52 .50 286.91
San Jacinto 3 .70 127 .95 24.00
San Patricio 29 .80 94 .07 89 .11
Schleicher 117 .95 416.02
Scurry 155 .28 224 .80 96 .96
Shackelford 206.38
Shelby 546 .60 881.58
Sherman 274.40 80 .60
Smith 6 .50 108.75 185 .85
Somervell 144 .00
Starr 69.53 1,406 .17 178.30
Stephens 469.77 14.40
Sterling 40.42 294 .86 9.25
Stonewall 221.08
Sutton 740 .80 1,866 .84 7 .20
Tarrant 37.45 18 .00 7 ,630 .70
Taylor 69.30 4 .00
6-11
Table 6.5 2008 Total Depth by Model Rig Well Type Category (1,000 feet) (Cont.)
County Vertical<= 7,000 feet Vertical > 7,000 feet Directional/Horizontal
Terrell 79 .8 5 295.70 92 .95
Terry 26.89 86.20 55 .20
Throckmorton 90.84
Titus 4 .60
Tom Green 123.60 16 .00
Trinity 4 .10
Tyler 23.11 70.20 329.95
Upshur 11 .77 260 .21 96.80
Upton 78.50 4 ,699.94 288.60
Val Verde 3.10 73 .30
Van Zandt 8.20 35.20
Victoria 296.15 207.20 33.03
Walker 4.90
Waller 82.71 61.80 10.00
Ward 460.51 161.91 482 .33
Washington 6.00 42 .00
Webb 262 .53 1,689.96 305.77
Wharton 239.83 586.42 114.77
Wheeler 3,839 .70 482.40
Wichita 366.76 9.00
Wilbarger 126.99
Willacy 301.75 25.50
Wilson 4.45
Winkler 20.50 294.95 148 .92
Wise 93.50 121.00 2,032 .78
Wood 17 .70 37.86 32 .00
Yoakum 462 .25 195.22 171.10
Young 259.30
Zapata 6.00 2,031.18 500.35
Zavala 16.05 60.20
Statewide Total 20 ,746 82 ,337 48 ,121
Appendix E contains a summary of the total well depth by county and year for each
model rig well type category.
6.2 Model Rig Emission Profiles
6.2.1 Model Rig Engine Profiles
As described in Section 5.2, the survey data was disaggregated into three model rig
categories for the following well types and depths based on the results of the data collection
survey:
• Vertical wells less than or equal to 7,000 feet;
6-12
• Vertical wells greater than 7 ,000 feet ; and
• Horizontal/Directional wells.
For each of these rig categories, a model rig engine profile was developed. In order for
the model rig engine profile data to be applied consistently to the TRC activity data , the survey
results were normalized to a 1,000 foot drilling depth . This was accomplished by dividing the
total drilling hours for each engine included in each survey by the well depth for that survey to
obtain the hours of operation per engine per 1,000 feet of drilling depth.
As the engine profiles and functions for engines used on mechanical rigs and electrical
rigs are distinctly different as described in Section 3.3, separate engine profiles for mechanical
and electrical rigs were developed for each model rig well type category.
The following average engine parameters were calculated for each model rig well type
category using a weighted average for each parameter based on the number of wells associated
with each survey:
• Number of engines by rig type (i.e., mechanical draw works, mud pumps, and
generators ; electrical rig engines; and completion engines).
• Engine age
• Engine size (hp)
• Engine on-time (hours/1,000 feet drilled)
• Overall average load (%)
Surveys with missing data parameters were excluded from the weighted average
calculation. The weighted averaged engine parameters developed for each model rig category by
rig type are summarized in Table 6-6.
6-13
Table 6.6 Model Rig Engine Parameters
Model Rig Rig Type Engine # of Average Engine Hours/1,000 Average
Cate2ory Type En2ines A2e (yrs) Size (hp) ft drilled Load(%)
Vertical <= Mechanical Draw Works 1.60 7 442 30 .8 51.8
7 ,000 ft 1 Mud Pumps 1.69 6 428 29.4 45 .9
Generator 0.97 4 330 28 .3 70.4
Vertical Mechanical Draw Works 2 .01 25 455 35 .9 47.4
> 7,000 ft Mud Pumps 1.62 18 761 33 .2 46 .0
Generator 2 .00 10 407 19.3 78.7
Electrical 2.15 2 1,381 62 .6 48 .5
Horizontal/ Mechanical Draw Works 2 .00 15 483 50 .l 41.1
Directional Mud Pumps 2.00 6 1,075 36.4 42.6
Generator 2.00 10 390 26 .8 69 .0
Electrical 2.03 2 1,346 47.3 52.5
All A ll Completion 1.00 Default 350 10.0 43 .0
1 The one electncal ng surveyed for vertical wells <= 7,000 feet represents less than 0 .5% of the total wells in this
model rig well type category and was considered to have a negligible contribution to the emi ssions profile.
As can be seen in Table 6-6, the expected trend toward larger engine sizes and more
hours required per 1,000 feet for the deeper vertical wells and the horizontal/directional wells is
verified. The older engine ages for the mechanical rigs used on the deeper vertical wells and the
horizontal/directional wells are based on several surveys received for these well types that
covered a large number of wells drilled by rigs with older engines. However, as noted in Section
3 .3 , the future trend for these types of wells is towards the use of electrical rigs , and the average
age of the engines used on the electrical rigs for these well types is only two years.
6.2.2 Model Rig Emission Factors
Once the final mechanical and electrical rig engine profiles were established for each
model rig well type category, US EPA's NONROAD model was used to develop criteria
pollutant emission factors for each rig type for each year of the inventory (2002, 2005, and
2008 -2021). Use of the NONROAD model allowed for expected reductions in emissions over
time due to the phasing in of EPA' s emissions standards for nonroad diesel engines .
Using the engine parameters summarized in Table 6-6 , NONROAD model input files
were developed (U.S. EPA, 2005). In particular, the NONROAD Activity file was modified
using the hours per 1,000 feet drilled and average load , while the Population files were modified
using the engine size. In addition, the population for a particular engine type was adjusted to a
unit value of 1 for ease in calculation. The modified NONROAD files used in the emission factor
calculation have been provided to the TCEQ in electronic format.
6-14
A total of 16 years were modeled -the base year of 2008, the prior years of 2002 and
2005, and 13 projected years from 2009 to 2021. For each year modeled, the engine model age
was kept constant. For instance , the 7 year old mechanical draw works engine for vertical wells<
7 ,000 feet was modeled as a 2001 model year engine for the 2008 base year, as a 1995 model
year engine for 2002, and as a 2014 model year engine for the future year of 2021.
The model year-specific emissions output from the NONROAD model (i.e., based on the
model year fraction of the unit engine population specified by the NONROAD population file)
was then ratioed up to the number of engines in each rig type. 2 For mechanical rigs, the draw
works, mud pump, and generator engine emissions were aggregated together. For both
mechanical and electrical rig types, a single completion engine of 350 hp running 10 hours per
1,000 feet drilled was also included to model completion activities. A composite model rig
emissions profile was developed by aggregating the mechanical and electrical rig types together
based upon the percentage of wells associated with each rig type. For example, for the
horizontal/directional model rig well type, approximately two-thirds of the wells were
represented by electrical rigs, so the resultant emission factors are weighted two-thirds by the
NONROAD electrical rig emission factors, and one-third by the mechanical rig emission factors.
S02 emissions are based on fuel sulfur content profiles for Texas obtained from historical
fuel sampling data performed for the TCEQ. The average diesel sulfur content(% weight) for a
particular analysis year was developed using the county-level fuel parameter data contained in
TCEQ's TexN model, weighted by the number of wells in each county. The statewide average
diesel sulfur content values calculated were 0.2995% for 2002 and 2005, 0.0316% for 2008 and
2009, and 0.0015% for 2010 through 2021, reflecting the reduced sulfur requirements over time .
Total hydrocarbon (THC) exhaust emissions from the NONROAD model were converted
to VOC and TOG using ratios of 1.053 and 1.070, respectively (U.S. EPA, 2005a). Crankcase
THC emissions were assumed to be equivalent to both VOC and TOG (U.S. EPA, 2005b). For
diesel nonroad engines, PM 10 is assumed to be equivalent to PM, while the PM2 .5 fraction of
PM 10 is estimated to be 0.97 (U.S. EPA, 2005a).
Hazardous air pollutant (HAP) emission factors were then developed by applying
speciated HAP emissions profiles for PM,0 and TOG from the California Air Resources Board's
2 The NON ROAD model allocates the total equipment population across a distribution of model years and estimates
the emissions associated with each model year. For a given calendar year this analysis is interested in just one
engine age/model year representing the average age for each model profile. Therefore the emissions for the model
year of interest were scaled back up as if the entire engine population specified in NON ROAD were allocated to just
this one model year.
6-15
(CARB) Speciation Profile Database for diesel combustion to the PM and TOG emissions
factors obtained from the NONROAD model (ARB, 2001). ARB profile #425 was used to
speciate PM to, and ARB profile #818 was used to speciate TOG. Tables 6-7 and 6-8 present the
speciation profiles for PMto and TOG, respectively.
Table 6.7 PM10 Speciation Factors
Weight
Fraction of
HAP HAPCAS# PMlO
Antimony 7440360 0.000036
Arsenic 7440382 0.000005
Cadmium 7440439 0.000040
Cobalt 7440484 0.000011
Chlorine 7782505 0 .000344
Lead 7439921 0 .000042
Manganese 7439965 0 .000040
Nickel 7440020 0 .000019
Mercury 7439976 0.000030
Phosphorous 7723140 0.000127
Selenium 7782492 0.000010
Table 6.8 TOG Speciation Factors
Weight
Fraction of
HAP HAPCAS# TOG
1,3-butadiene 106990 0 .002
2,2,4-trimethylpentane 540841 0.003
Acetaldehvde 75070 0.074
Benzene 71432 0.02
Cumene 98828 2E-04
Ethylbenzene 100414 0 .003
Formaldehyde 50000 0.147
Methanol 67561 3E-04
m-xylene 108383 0.006
Naphthalene 91203 9E-04
n-hexane 110543 0 .002
o-xylene 95476 0.003
Propionaldehvde 123386 0 .01
p-xylene 106423 0 .001
Stvrene 100425 6E-04
Toluene 108883 0.015
The final emissions profile for each of the three model rig well type categories was
developed by weighing the emission profiles for each rig type (mechanical and electrical) by the
6-16
percentage of wells of each rig type in each model rig well type category. Appendix F presents
the emission factors developed for each of the model rig well type categories for 2002, 2005, and
2008 through 2021.
6.3 Emission Estimation Methodology
Using the model rig well type category emission profiles, county-level emission estimates
were calculated using the activity data from the TRC dataset. County-level well activity data in
terms of total depth (1,000 feet) drilled was obtained by summing the depth of each individual
well drilled for each of the three model rig well type categories for each county as described in
Section 6.1. Once the total depth drilled by model rig well type category was known and the
emission factor profile for each model rig well type category was developed, annual county level
emissions for each model rig well type category were estimated by multiplying the total depth
drilled (in terms of 1,000 feet) by the emission factors obtained through use of the survey data
and the NONROAD model as follows:
Ep 0 11 -ty pe= (Depth (1 ,000 feet/yr)) x (EFp oll (tons/1 ,000 feet))
Where:
Epoll -ty pe
Depth
EFp oll
Emissions of pollutant for county by model rig well type
category (tons/yr)
Total depth drilled in model rig well type category by county
(1 ,000 feet/yr)
Emission factor of pollutant (tons/1,000 feet)
For 2008 through 2021 , NO x emission estimates for the 110 counties subject to the Texas
Low Emission Diesel (TxLED) program were adjus ted downward by 6.2% to account for the
effect of the rule.3 Table 6-9 identifies the counties where this adjustment was made .
Table 6.9 TxLED Counties
Anderson Denton Johnson Robertson
Angelina Ellis Karnes Rockwall
Aransas Falls Kaufman Rusk
Atascosa Fannin Lamar Sabine
Austin Fayette Lavaca San Jacinto
Bastrop Franklin Lee San Patricio
Bee Freestone Leon San Augustine
3 The TxLED program requirements initiated in February 2006 , so these adjustments were not applied to the 2002
and 2005 modeling scenarios.
6-17
Table 6.9 TxLED Counties (Cont.)
Bell Fort Bend Liberty Shelby
Bexar Gal veston Limestone Smith
Bosque Goliad Live Oak Somervell
Bowie Gonzales Madison Tarrant
Brazoria Grayson Marion Titus
Brazos Gregg Matagorda Travis
Burleson Grimes McLennan Trinity
Caldwell Guadalupe Milam Tyler
Calhoun Hardin Montgomery Upshur
Camp Harris Morris Van Zandt
Cass Harrison Nacogdoches Victoria
Chambers Hays Navarro Walker
Cherokee Henderson Newton Waller
Collin Hill Nueces Washington
Colorado Hood Orange Wharton
Comal Hopkins Panola Williamson
Cooke Houston Parker Wilson
Coryell Hunt Polk Wise
Dallas Jackson Rains
De Witt Jasper Red River
Delta Jefferson Refugio
For counties subject to TxLED requirements , NO x emissions were estimated as follows:
E Nox-type = (Depth (1 ,000 fee t/yr)) x (EFNo x (tons/1,000 feet)) x (0 .938)
Where:
E Nox -type
Depth
EF Nox
(0.938)
Emissions of NOx for each county by model rig well type
category (tons/yr)
Total depth drilled in model rig well type category by county
(1 ,000 feet/yr)
NOx emission factor (tons /1,000 feet)
Adjustment Factor to account for 6.2 % TxLED reduction
Total county level annual emissions were then obtained by summing the total emissions
for each of the three model rig well type categories for each county. Ozone season daily (OSD)
emissions were calculated by dividing the annual emissions by 365 (days/year).
6-18
6.4 Results
6.4.1 Emission Summary
Table 6-10 summarizes the statewide annual criteria pollutant emis sion estimates for
2002 , 2005 , and 2008 through 2021. Table 6-11 summarizes both annual and OSD criteria
pollutant emissions by county for the 2008 base year. Appendix G contains detailed tables
showing statewide annual emission estimates for each year for all criteria pollutants and HAPs
(Appendix G , Table l), a s well as county-level annual and OSD emi s sion estimate s for each year
for all criteria pollutants and HAPs (Appendix G , Tables 2 and 3 , respectively). The decreasing
emissions after 2009 reflecting the falling oil and gas production projections from the EIA
dataset for the areas including Texas.
As compared to the previous oil and gas study prepared by TCEQ in 2007 (for a 2005
base year), the emission estimates presented in this study reflect a significant decrease in the
statewide NO x emission estimate from drilling rig engines for 2005 (42 ,854 tons per year in thi s
study compared to 119 ,647 tons per year in the 2007 study). While not as pronounced, there
were also significant decreases in the S02 and CO emission estimates based on this study. For
VOC , PM1 o, and PM2.5 , the estimates contained in this study show slightly higher estimates than
in the previous study . These differences in the estimates between the two studies can be
attributed to the emissions estimation methodologies used in each study . While the previous
study was done using a top-down approach , conservative emission estimation assumptions , and
the use of AP-42 emission factors , the current study used 2008 survey data on the actual engine
parameters ( engine size, hours of operation , and engine load) used in drilling oil and gas wells in
2008 , as well as utilizing the NONROAD model to develop emission factors .
6.4.2 NIF 3.0 Files
Once the emissions inventory was completed, NIF 3.0 area source text-formatted input
files were prepared for base years 2002, 2005 , and 2008. The NIF 3.0 files were created using
information provided by TCEQ regarding the correct format and valid code listings for submittal
to TexAER (TCEQ 2009a). Prior to submittal to TCEQ , the NIF 3.0 files were pre-processed
using EPA 's NIF Basic Format and Content Checker to check for errors and inconsistencies .
Additionally, ERG performed a test upload to TexAER to ensure the files were complete and
accurate and in a format consistent with the TexAER area source file data requirements.
6-19
Table 6.10 Texas Drilling Rig Estimates (tons/year) Year co ·NOx PM10 PM2.5 S02 voe 2002 13,305 35,828 2,552 2,475 4,776 3,631 2005 15,878 42,854 3,036 2,945 5,977 4,337 2008 16,721 55,238 2,543 2,467 956 4,326 2009 16,769 55,457 2,550 2,474 961 4,340 2010 16,336 53,123 2,417 2,344 45 4,182 2011 15,117 48,462 2,319 2,249 44 3,806 2012 14,748 46,253 2,263 2,196 43 3,665 2013 12,008 39,793 1,378 1,337 38 3,413 2014 11,945 39,461 1,372 1,331 38 3,392 2015 11,755 38,837 1,350 1,310 37 3,349 2016 11,558 36,440 1,320 1,280 37 3,320 2017 8,915 34,771 1,118 1,085 36 2,800 2018 6,114 31,282 811 787 35 2,227 2019 6,073 31,127 805 781 35 2,215 2020 6,035 30,771 800 776 35 2,205 2021 3,299 26,063 448 435 33 1,504 6-20
Table 6.11 2008 Annual and OSD County-Level Criteria Pollutant Emission Estimates
NOr:. NOx-PJ\110-Jiffe" PM1r, ?Mu· PM2.s-voe-voe,,~\,
00.ANN CO-OSD ANN ' OSD ANN OSD ANN OSD SOrANN SOrOSD ANN OSD
County tons/yr tons/day tons/yr tons/day tonslYr tons/day tons/yr tons/day tons/vr tons/day tons/vr tons/dav
Anderson 2.03E+Ol 5.53E-02 5 .94E+Ol l.62E -O I 3 .IOE+OO 8.47E-03 3.0IE+OO 8 .21E-03 l.04E+OO 2.83E-03 5 .1 lE+OO 1.40£-02
Andrews 2.33 E+02 6.36E-Ol 7.75 E+02 2.12 E+OO 3.52E+Ol 9 .61 E-02 3.41 E+Ol 9 .33E-02 l.37E+Ol 3.74E-02 5 .64E+Ol l.54E-O l
Angelina 6 .70E+Ol l.83E-Ol l.93E+02 5 .27 £-01 l.03E+Ol 2 .8 2£-02 l.OO E+Ol 2 .73E-02 3 .26E+OO 8 .91 £-03 l.72E+Ol 4 .71£-02
Aransas 8 .80E+OO 2.41£-02 2 .75E+Ol 7 .5 LE -02 l.34E+OO 3 .67E-03 l .30E+OO 3 .56£-03 4 .85 £-01 l .32£-03 2 .2 8E+OO 6.23E-03
Archer 9 .32E+OO 2 .55£-02 3.94E+Ol l.08E-Ol l .35 E+OO 3 .68£-03 l.3IE+OO 3.57E-03 8 .l lE-01 2 .22£-03 2 .05E+OO 5.61£-03
Atascosa 7.02E+OO 1.92£-02 2 .05E+Ol 5 .61£-02 l .07E+OO 2 .93E-03 1.04E+OO 2 .8 4£-03 3 .69 E-Ol l.OIE-03 l.72E+OO 4.71E-03
Austin 7.59E+OO 2 .07£-02 2 .63E+Ol 7.20£-02 l.13E+OO 3 . IOE-03 1.IOE+OO 3 .0IE-03 5 .13E-01 1.40£-0 3 1.87E+OO 5 .IOE-03
Bastrop l.69E+Ol 4 .63£-02 5 .76E+Ol l.57E-01 2 .56E+OO 7 .0LE-03 2.49E+OO 6 .8 0£-03 l.04E+OO 2 .8 5£-03 4.46E+OO l.22E-02
Baylor l .87E+OO 5 . LOE-03 9 .04E+OO 2.47£-02 2 .65E-Ol 7.24£-04 2 .57E-Ol 7.02£-04 l.90E-O I 5 .19£-04 4 .23£-01 1. l 6E -03
Bee 5.68E+Ol l .55£-01 2 .06£+02 5.62£-01 8 .51E+OO 2.32£-02 8 .25E+OO 2 .25£-02 3.92E+OO l.07£-02 l.47E+Ol 4 .0IE-02
Bell 1.42£-01 3 .89£-04 6.28£-01 1.72£-03 2.0IE-02 5.49£-05 1.95£-02 5.32£-05 1.45£-02 3 .97£-05 2 .98£-02 8.14£-05
Bexar 2.53£-02 6 .92£-05 1.12£-0 l 3.05£-04 3.57£-03 9 .76£-06 3.46£-03 9.47£-06 2.58£-03 7.06£-06 5 .30£-03 1.45£-05
Borden 2 .86E+Ol 7 .80£-02 8 .82E+Ol 2.41£-0 l 4 .39E+OO 1.20£-02 4 .25E+OO 1.16£-02 l.41E+OO 3 .85£-03 7.32E+OO 2.00E-02
Bosque 2 .72E+OO 7.44£-03 9 .98E+OO 2.73£-02 4 .09£-01 1.12£-03 3.97£-01 1.08£-03 l.85E-Ol 5.06E-04 7 .29£-01 l .99E-03
Bowie l.35 E+OO 3.68E-03 3 .50E+OO 9 .57£-03 2 .09£-01 5.70£-04 2.03E-Ol 5.53£-04 5 .63E-02 1.54£-04 3.41E-Ol 9 .32£-04
Brazoria 4 .64E+Ol 1.27£-01 l.40E+02 3 .84£-01 7.lOE+OO 1.94£-02 6.89E+OO 1.8 8£-02 2.44E+OO 6 .65£-03 l.20E+Ol 3.27£-02
Brazos 2.17 E+Ol 5.92£-02 9 .57E+Ol 2 .62£-01 3.18E+OO 8.69£-03 3 .09E+OO 8 .43£-03 l .88 E+OO 5.13E-03 6 .02E+OO 1.64£-02
Briscoe l.48E+OO 4.04£-03 4.49E+OO l .23E-02 2 .26£-01 6 .18£-04 2.19£-01 6 .00E-04 7.41£-02 2.02£-04 3 .65£-01 9 .98£-04
Brooks 9.58E+Ol 2 .62£-01 2.87£+02 7.84£-01 l.48E+Ol 4 .03 £-02 1.43E+Ol 3 .91£-02 4 .50E+OO l.23E-02 2 .45E+Ol 6.69£-02
Brown l .30E+OO 3.54£-03 6.IO E+OO 1.67£-02 1.83£-01 5 .00E-04 1.78£-01 4 .85£-04 1.32E-Ol 3.62 £-04 2 .71E-Ol 7 .42£-04
Burleson 4.46E+Ol l .22E-Ol 1.48£+02 4 .04£-01 6 .77E +OO 1.85£-02 6.57E+OO 1.80£-02 2 .65E+OO 7.2 3£-03 l.17E+Ol 3.21£-02
Caldwell l.58E+OO 4 .31£-03 7.31E+OO 2 .00E -02 2.25E-01 6 .14£-04 2 .18E-Ol 5 .96£-04 l.60E-01 4 .36£-04 3 .78E-Ol l.03E-03
Calhoun 2.38E+Ol 6 .50£-02 7 .79E+Ol 2 .13£-01 3.61E+OO 9 .87£-03 3.50E+OO 9.57£-03 l.40E+OO 3 .82£-03 6.21E+OO l.70E-02
Callahan 2 .58E+OO 7.06£-03 l.22E+Ol 3.32E-02 3.65£-01 9 .96£-04 3.54E-OI 9 .67E-04 2 .64£-01 7.21E-04 5.41£-01 I .48E-03
Cameron l.42E+OO 3 .89£-03 3.94£+00 1.08£-02 2 .20E-OI 6 .02£-04 2 .14£-01 5.84£-04 5 .94£-02 1.62£-04 3 .60£-01 9 .84£-04
Carson 9 .90£-01 2 .71£-03 5 .12£+00 1.40£-02 1.42£-01 3 .89E-04 l.38E-Ol 3 .77E-04 9.95£-02 2.72£-04 2 .67£-01 7.29£-04
Cass 2 .22£-01 6 .05£-04 9.77£-01 2 .67£-03 3.13£-02 8 .54£-05 3 .03£-02 8.28£-05 2 .26£-02 6.17£-05 4.63£-02 1.27£-04
Chambers 2 .37£+01 6.47£-02 8.97E+Ol 2.45£-01 3 .55E+OO 9 .69E-03 3.44E+OO 9.40E-03 1.6 8£+00 4.60E-03 6 .38E+OO l.74E-02
Cherokee l .52 E+02 4 .15£-01 4.40£+02 1.20E+OO 2 .33E+Ol 6 .37E-02 2.26E+Ol 6 .18E-02 7.46E+OO 2 .04 E-02 3 .90E+Ol l.07E-Ol
Childress 2 .94E-01 8 .04£-04 l.38E+OO 3.7 8£-03 4 .15 £-02 1.13 E -04 4 .03 £-02 l . lO E-04 3.00E-02 8 .20£-05 6 .16£-02 l .68 E-04
6-21
Table 6.11 2008 Annual and OSD County-Level Criteria Pollutant Emission Estimates (Cont.)
A NOx-NOx-PM1r PM1r Pl\fu-PMu· v voe. voe-
CO-ANN CO-OSD ANN OSD ANN OSD ANN OSD SO,-ANN SO....OSD ANN OSI>'
County tonslvr tons/dav ,tons/vr . tons/dav toas/vr toas/dav tons/vr tons/dav tons/yr tons/dav tons/vr tons/day
Clay l.12E+Ol 3 .06E-02 4.84E+Ol l.32E-O 1 l.64E+OO 4.48E-03 l.59E+OO 4 .35E-03 9 .27E-Ol 2 .53E-03 2 .80E+OO 7.66E-03
Cochran l.lOE+O l 3.0lE-02 4.45E+Ol l.22E-Ol l.60E+OO 4 .38E-03 l.56E+OO 4 .25E-03 8 .97E-Ol 2.45E-03 2.47E+OO 6 .74E-03
Coke 6.20E+OO l.69E-02 2.46E+Ol 6.73E-02 9.08E-Ol 2.48E-03 8 .80£-0 1 2.41£-03 4 .9 1£-01 1.34£-03 1.40£+00 3.83£-0 3
Colem an 3.09E+OO 8.45£-03 1.45 £+0 1 3.97E-02 4.36£-01 l.l 9E-03 4.23E-Ol l.1 6E-0 3 3.15 E -Ol 8.62E-04 6.4 7£-01 l .77E-03
Colorado 2.83E+Ol 7 .73£-02 8.52E+OI 2.33£-01 4.31E+OO 1.18£-02 4 .18E+OO 1.14£-0 2 l.53E+OO 4 .18£-0 3 7.06E+OO 1.93£-02
Comanc he 9.49E-02 2.59£-04 4.46E-OI 1.22£-0 3 1.34£-0 2 3 .66£-05 l .30£-02 3 .55£-05 9.69£-03 2 .65£-05 l .99E-02 5.43£-05
Concho 5 .29E+OO I .45E-02 2.49E+Ol 6 .80E-0 2 7 .46E-Ol 2.04£-03 7.24E-Ol 1.98£-0 3 5.40£-01 1.47E-03 1.1 I E+OO 3 .02E-03
Cooke 4 .07E+OI 1.11 E-01 I .18E+02 3.24£-01 6.23E+OO 1.70£-02 6.04 E+OO 1.65£-02 2.09E+OO 5.71 E-0 3 1.0 lE+OI 2 .77£-02
Coryell 1.2 7£-0 I 3.46£-04 5.58E-Ol 1.53£-03 1.79E-02 4 .88E-05 l.73E-02 4 .73E-05 l .29E-0 2 3 .53E-05 2.65E-02 7 .23E-05
Cottle 1.78E+OI 4 .87E -0 2 5.34E+OI l .46E-OI 2 .74E+OO 7.49E-03 2 .66£+00 7.26E-0 3 8 .5 6E-Ol 2.34E-03 4.48E+OO l .22E-0 2
Crane 4.87E+Ol 1.33£-01 1.80£+02 4 .93£-0 1 7.25E+OO l .98E-02 7 .04E+OO 1.92£-02 3 .38E+OO 9.24E-03 l.1 6E+Ol 3. l 7E-02
Crock ett 3 .11£+02 8 .50£-01 9.41£+02 2 .57E+OO 4 .77E+Ol 1.30£-0 1 4 .63E+OI l .26E-O I l.53E+Ol 4 .l 7E-02 7.79£+01 2 .13£-01
Cros by 2.90£+00 7 .93£-0 3 l.36E+OI 3 .73E-02 4 .09£-01 1.12E-03 3 .97£-01 l.08E-03 2 .96£-01 8.09£-04 6 .07£-01 l.66E-03
C ulb erson 3 .59E+OI 9.8 0£-02 1.0 8£+02 2 .95£-01 5 .53E+OO l.5 I E-02 5 .36E+OO 1.46£-02 l.70E+OO 4 .64E-0 3 9.20E+OO 2.51£-02
D all as 7 .73£+00 2 .l lE-02 3.84£+01 1.05£-01 l.12E+OO 3.05E-03 l .08E+OO 2 .96£-03 7.73£-01 2.l lE-03 2.2 1E+OO 6.03E-0 3
D awson 5.66E+Ol I .55E-OI l.63E+02 4.45£-01 8 .73E+OO 2 .39£-02 8.47E+OO 2 .3 I E-02 2.52E+OO 6 .89£-03 l.4 3E+Ol 3 .91£-02
D enton 2 .06£+02 5 .62E-O I 9.93E+02 2 .71E+OO 2 .99E+O I 8.16£-02 2.90E+OI 7 .9 1E-02 l.99E+Ol 5.44E-02 5 .83E+OI l.59E -OI
D eWitt l .05 E+02 2 .86E-Ol 3 .80E+02 1.04£+00 l.57E+O I 4 .30E-0 2 l .53 E+O l 4.17E-02 7.06E+OO l .93E-02 2 .79E+OI 7 .6 1E -02
Dicke ns 2.40E+Ol 6 .56£-02 7 .72E+OI 2 .I I E-0 1 3 .65E+OO 9 .96£-0 3 3 .54E+OO 9 .66E-0 3 l.34E+OO 3.65£-0 3 5.84E+OO l .60E-02
Dimmit 4 .50E+Ol l.23E-O I 1.66E+02 4 .53E-Ol 6 .75E+OO 1.84£-0 2 6 .55E+OO l.79E-02 2 .96E+OO 8 .IOE-03 l.1 3E+O I 3 . IO E-0 2
Duval 7 .96E+Ol 2 .17E -OI 2 .39E+02 6 .53E-OI l .22E+OI 3.35£-02 l.19E+Ol 3 .25E -0 2 3 .78E+OO l.03 E-02 2.02£+01 5 .53 E-02
Eastl and l .52E+OO 4 .16£-0 3 7.16£+00 1.96£-0 2 2 .15 E -OI 5.8 7£-04 2.08£-01 5 .69£-04 1.55 £-01 4.24E-04 3.18£-01 8 .70£-04
Ector 2 .64E+02 7.21E-OI 7 .77£+02 2.12E+OO 4 .06E+OI I .I I E-01 3 .94 E+OI I .08E-O l l.23E+OI 3 .36E-02 6.64E+OI l.8 1E-O l
Edwards 3 .99E+OI l.09E-O l l.3 l E+02 3.58E-Ol 6.07E+OO l .66E-02 5 .89E+O O 1.61 E-02 2.20E+OO 6.0lE-03 l.OI E+OI 2.76 E-02
Ellis 2 .09E+OI 5.72E-02 l .04E+02 2.84E-O I 3.03E+OO 8 .27E-03 2 .94E+OO 8.02E-03 2.IOE+OO 5.73£-03 5.97E+OO l .63E-02
Erath 8.49E+OO 2 .32£-0 2 4.44E+OI l.2 1E-Ol l.22E+OO 3.3 4 E-0 3 l.l 9E+OO 3 .24£-03 8 .51 E-OI 2.33£-03 2.35E+OO 6.42£-03
Fall s 5.70£-02 l .56E-04 2.5 1E-OI 6 .8 7£-04 8.04£-03 2 .20E-05 7 .80E-03 2 .13E-05 5.8 1E-03 1.59£-05 l .19E-02 3 .26E-05
Fannin 2 .84E+OO 7 .77E-0 3 7 .39E+OO 2 .02E-02 4.41 E-O l l .20E-03 4 .28E-Ol l .l 7E-03 l.l 9E-O 1 3.24£-04 7.20£-01 l .97E-03
Fayette l.l l E+O l 3 .03E-02 4 .69E+OI l.28E-Ol l.63E+OO 4.46E-03 l .58E+OO 4 .33E-03 9.16E-Ol 2 .50E-03 3.02E+OO 8.24E-03
Fi sher l .54E+Ol 4 .20E-02 5 .25E+O l l.44E -OI 2.31E+OO 6 .3 I E-03 2.2 4E+OO 6.12 E-03 9 .52E-OI 2.60£-03 3 .67E+OO I.OO E-02
6-22
Table 6.11 2008 Annual and OSD County-Level Criteria Pollutant Emission Estimates (Cont.)
,,
NOx-+1; NO,r: PM'10-fMur ,, , JlM~!!"' PMu:, -~w,, <J % Voe-.. ~ \1., VOC:,tt:. ""'
CO:ANN CO-OSD ANN .::c.;;"' OSD 0 ANN ,A:(}SD ANN s OSD SOr:ANN so!osn ANN •* OSD
County tons/vr toos/dav toos/vr toos/dav toos/vr tons/dav toos/vr toas/dav toas/vr toas/dav tonslvr toas/dav
Foard 7 .94E-Ol 2.l 7E-03 3.74E+OO l.02E-02 l.12E-Ol 3.06E-04 l.09E-OI 2.97E-04 8.lOE-02 2.21E-04 l.66E-Ol 4 .54E-04
Fort Bend 2.60E+OI 7.09E-02 9.96E+Ol 2.72E-OI 3.85E+OO l.05E-02 3.73E+OO l.02E-02 l .95E+OO 5.34E-03 6 .66E+OO l.82E-02
Franklin 1.45E+Ol 3 .96E-02 3.83E+OI I .05E-Ol 2 .24E+OO 6.13E-03 2 .17E+OO 5 .94E-03 6 .26E-Ol 1.71E-03 3.66E+OO 9 .99E-03
Freestone 4.35E+02 l.19E+OO l .22E+03 3 .33E+OO 6 .70E+OI l.83E-Ol 6 .50E+Ol l .77E-Ol 2.04E+Ol 5.56E-02 l.l 1E+02 3.04E-Ol
Frio l .91E+Ol 5 .21 E-02 7.43E+Ol 2.03E-Ol 2.84E+OO 7.75E-03 2 .75E+OO 7 .52E-03 l.37E+OO 3.74E-03 4 .77E+OO 1.30E-02
Gaines l.l2E+02 3.07E-Ol 3.47E+02 9.48E-OI l.72E+Ol 4.69E-02 l.66E+Ol 4 .55E-02 5.72E+OO l.56E-02 2.80E+OI 7 .65E-02
Galveston l.l9E+Ol 3 .26E-02 4.1 lE+Ol l.l2E-Ol l.81E+OO 4 .93E-03 l.75E+OO 4 .78E-03 7.49E-Ol 2.05E-03 3 ,JS E +OO 8.61E-03
Garza l.40E+Ol 3.83E-02 5.1 JE+Ol I .39E-Ol 2.09E+OO 5.70E-03 2.02E+OO 5 .53E-03 9.61E-Ol 2 .63E-03 3 .30E+OO 9.00E-03
Glasscock l .36E+02 3.72E-Ol 3.81E+02 l .04E+OO 2.1 IE+OI 5.76E-02 2 .05E+Ol 5 .59E-02 5 .78E+OO l.58E-02 3.46E+Ol 9.44E-02
Goliad 6.97E+Ol l.91E-OI 2 .09E+02 5.70E-OI l.06E+Ol 2.91E-02 l.03E+OI 2.82E-02 3 .70E+OO 1.0IE-02 l.75E+Ol 4.79E-02
Gonzales 5 .35E+OO l.46E-02 l.87E+Ol 5. l2E -02 8.04E-Ol 2 .20E-03 7 .80E-Ol 2.13E-03 3.50E-Ol 9.57E-04 l.39E+OO 3 .79E-03
Gray 2 .33E+OO 6 .37E-03 7 .20E+OO l.97E-02 3 .56E-Ol 9.72E-04 3.45E-Ol 9.43E-04 1.20E-Ol 3 .29E-04 5 .73E-Ol l .57E-03
Grayson l.07E+Ol 2.91E-02 3 .54E+Ol 9 .66E-02 l.62E+OO 4.42E-03 l .57E+OO 4.28E-03 6.40E-Ol l.75E-03 2 .78E+OO 7 .59E-03
Gre!!:!!: 9 .58E+Ol 2 .62E-Ol 2 .97E+02 8.12E-O l I .46E+Ol 4.00E-02 l.42E+Ol 3 .88E-02 5.19E+OO l.42E-02 2.49E+Ol 6.81E-02
Grimes l.33E+Ol 3.64E-02 6 .59E+Ol l .80E-Ol l.92E+OO 5.25E-03 l.86E+OO 5.09E-03 l.33E+OO 3.64E-03 3.79E+OO l.03E-02
Guadalupe 8 .96E-OI 2.45E-03 4.29E+OO l .l 7E-02 l.29E-Ol 3 .51E-04 l .25E-Ol 3.41E-04 9 .02E-02 2.47E-04 2.34E-Ol 6 .38E-04
Hale 3.22E+OO 8.80E-03 l.58E+OI 4.33E-02 4 .59E-OI l .25E-03 4.45E-OI l .22E-03 3 .26E-OI 8 .92E-04 7.63E-OI 2 .08E-03
Hansford 4 .53E+OI l.24E-OI l.39E+02 3.80E-OI 6 .95E+OO I .90E-02 6 .74E+OO I .84E-02 2.24E+OO 6.l lE-03 l.lSE+OI 3.14E-02
Hardeman l.70E +OI 4.65E-02 5 .35E+OI I .46E-OI 2 .61E+OO 7 .13E-03 2.53E+OO 6 .92E-03 8.64E-OI 2.36E-03 4 .37E+OO I .19E-02
Hardin 5 .91E+Ol l.62E-OI l .92E+02 5 .23E-Ol 8 .98E+OO 2.45E-02 8 .71E+OO 2 .38E-02 3.44E+OO 9 .40 E-03 l.53E+OI 4 .18E-02
Harris 1.24E+Ol 3.38E-02 4 .89E+Ol l .34E-Ol l.84E+OO 5.02E-03 l .78E+OO 4 .87E-03 9.40E-Ol 2.57E-03 3.32E+OO 9 .06E-03
Harrison 5.79E+02 l.58E+OO 1.84E+03 5 .04E+OO 8 .82E+Ol 2.41E-Ol 8.55E+Ol 2.34E-01 3 .26E+Ol 8 .91E-02 l.51E+02 4.13E-Ol
Hartley 5 .68E-Ol l.55E-03 2 .67E+OO 7 .30E-03 8 .0IE-02 2 .19E-04 7 .77E-02 2 .12E-04 5 .80E-02 l .58E-04 l.1 9E-OI 3 .25E-04
Haske ll 2.02E+OO 5 .51 E-03 9.48E+OO 2.59E-02 2.84E-Ol 7 .77E-04 2 .76E-OI 7.54E-04 2.06E-OI 5 .62E-04 4 .22E-01 l.l 5E-03
Hemphill 6.43E+02 l.76E+OO l.92E+03 5 .23E+OO 9.90E+Ol 2.71E-Ol 9.61E+Ol 2 .62E-Ol 3 .00E+Ol 8 .18E-02 l.64E+02 4 .49E-Ol
Henderson 3.91E+OI l .07E-OI I.I I E+02 3.04E-OI 6.0IE+OO l.64E-02 5 .83E+OO l .59E-02 l .87E+OO 5.12E-03 I .OOE +Ol 2.74E-02
Hidalgo 2.27E+02 6 .19E-OI 6.98E+02 l.91E+OO 3.48E+Ol 9 .51E-02 3 .38E+OI 9 .23E-02 1.1 !E+OI 3 .03E-02 5 .82E+OI l.59E-OI
Hill 9 .04E+OI 2.47E-01 4.49E+02 1.23E+OO l.31E+OI 3.57E-02 1.27E+OI 3.46E-02 9 .05E+OO 2.47E-02 2 .58E+OI 7.04E-02
Hockley 3 .19E+Ol 8 .71E-02 l.18E+02 3 .23E-OI 4.77E+OO l.30E-02 4 .63E+OO l .27E-02 2 .12E+OO 5.80E-03 8.00E+OO 2 .18E-02
Hood 7 .86E+Ol 2. I 5E-OI 3 .90E+02 l .07E+OO l.13E+Ol 3 .IO E-02 l.lOE+Ol 3 .0IE-02 7 .86E+OO 2 . l SE-02 2 .24E+OI 6.12E-02
6-23
Table 6.11 2008 Annual and OSD County-Level Criteria Pollutant Emission Estimates (Cont.)
NOx; NOx-PM1r PM1r PMu-PMu-voe-voe-
CO-ANN CO-OSD ANN OSD ANN OSD ANN OSD SO.-ANN SOr-OSD ANN OSD
Coupty toos/vr tons/day tons/vr tons/dav toas/vr tons/dav tons/vr tons/dav tons/vr toos/dav tonslvr tons/day
Hopkins 3.41E+OO 9.31£-03 9.1 lE+OO 2.49£-02 5 .26£-01 1.44£-03 5.lOE-0 1 1.39£-03 l.5 lE-01 4 .12£-04 8 .56£-01 2.34£-03
Houston 2 .89E+Ol 7 .8 9£-02 8.59E+Ol 2.35£-01 4.43E+OO l .21£-02 4 .29E+OO l .17£-02 l.48E+OO 4 .04£-03 7.44E+OO 2.03£-02
Howard l.19E+02 3.26£-01 3 .36£+02 9.17£-01 l.85E+Ol 5.04£-02 l.79E+Ol 4 .89£-02 5.14E+OO 1.40£-02 3 .0lE+Ol 8.23£-02
Hudspeth 4.12E+OO l .12£-02 l.30E+Ol 3 .55£-02 6 .26£-01 1.7 lE-03 6.08£-01 1.66£-03 2.21£-01 6.05£-04 1.0lE+OO 2.75£-03
Hutchinson l.55E+Ol 4 .2 4£-02 6.98E+Ol 1.91 E-01 2.24E+OO 6.l lE-03 2 .l7E+OO 5 .92E-03 l.42E+OO 3.89E-03 3.59E+OO 9 .81 E-03
Irion 2.33E+02 6.36E-Ol 6.57E+02 l.79E+OO 3 .60E+Ol 9 .83E-02 3.49E+OI 9.54E-02 l.OIE+Ol 2 .76E-02 5 .8 7E+Ol l.60E-Ol
Jack I .69E+Ol 4.63E-02 8.59E+Ol 2 .35E-Ol 2.43E+OO 6 .63E-0 3 2.35E+OO 6.43E-03 1.7 I E +OO 4 .66E-03 4 .36E+OO I .19E-02
Jackson 5.69E+Ol l.56E-OI l.66E+02 4 .53E-Ol 8.70E+OO 2.38E-02 8.44E+OO 2.3 lE-02 2.92E+OO 7 .97E-03 l.42E+OI 3.88E-02
Jasper 2.20E+OI 6.02E-02 9 .34E+Ol 2.55E-01 3.25E+OO 8 .88E-03 3.15E+OO 8 .61E-03 l.81E+OO 4 .96E-03 6 .05E+OO l.65E-02
Jefferson 4.90E+Ol I .34E-OI 1.8 4E+02 5.03E-Ol 7 .34E+OO 2 .0lE-02 7 .12 E+OO l .95E-02 3.46E+OO 9 .44E-03 l.31E+OI 3.59E-02
Jim Horrrr 3 .05E+Ol 8 .33E-02 8 .78E+OI 2.40E-Ol 4 .71E+OO l.29E-02 4 .57E+OO l.25E-02 l.36E+OO 3.70E-03 7.74E+OO 2.12E-02
Jim W e ll s l.IOE+Ol 3 .0lE-02 3 .69E+Ol l.OIE-01 l .6 7E+OO 4 .56E-03 l.62E+OO 4.42E-03 6.49E-Ol l.77E-03 2.69E+OO 7 .36E-03
Johnson 6 .62E+02 l.81E+OO 3.27E+03 8.93E+OO 9.57E+Ol 2 .62E-Ol 9.28E+Ol 2.54E-OI 6.58E+OI l.80E-01 l.89E+02 5. l 5E-OI
Jones 7.02E+OO l.92E-02 3 .30E+Ol 9 .02E-02 9 .9 1E-Ol 2.71E-03 9.61E-Ol 2.63E-03 7 .17E-OI l .96E-03 1.4 7E+OO 4.0IE-03
Karnes 2 .97E+OI 8.12E-02 I. I 1E+02 3 .05E-Ol 4.45E+OO l .22E-02 4 .32E+OO l .18E-02 2 .lOE+OO 5 .73E-03 7.95E+OO 2.l 7E-02
Kenedy 6.47E+Ol l.77E-Ol l.98E+02 5.40E-O 1 9.94E+OO 2 .72E-02 9 .64E+OO 2.63E-02 3 .13E+OO 8 .56E-03 l.66E+Ol 4 .53E-02
Kent 2.31E+Ol 6.30E-02 7 .83E+OI 2.14E-Ol 3.49E+OO 9.54E-03 3 .39E+OO 9.25E-03 l.36E+OO 3.71 E-03 5.76E+OO I .57E-02
King 7.56E+OO 2 .07E-02 3.34E+O l 9.13E-02 l.08E+OO 2.96E-03 l.05E+OO 2.87E-03 7 .05E-Ol l .93E-03 l .63E+OO 4.45E-03
Kleberg I .98E+Ol 5.42E-02 8.43E+Ol 2 .30E-Ol 2 .95E+OO 8 .06E-03 2 .8 6E+OO 7 .82E-03 l.51E+OO 4 .l2E-03 5.39E+OO l .47E-02
Knox 2.79E+OO 7.63E-03 1.1 IE+Ol 3 .02E-02 4.09E-OI 1. l 2E-03 3.97E-OI l .08E-03 2.20E-O l 6.0 IE -04 6 .32E-OI l.73E-03
La Salle l.07E+02 2.92E-Ol 3 .04E+02 8 .32E-Ol l .6 5E+Ol 4 .52E-02 l.60E+Ol 4.38E-02 4 .68E+OO l .28E-02 2.71E+OI 7.40E-02
Lamb l .62E+OO 4.43E-03 7.96E+OO 2.18E-02 2.31E-Ol 6 .30E-04 2 .24E-O l 6.l lE-04 1.64E-Ol 4.49E-04 3 .83E-OI l .05E-03
Lavaca 1.03E+02 2 .8 1E-Ol 3 .14E+02 8.57E-Ol 1.57E+Ol 4.30E-02 l.53E+Ol 4. I 7E-02 5.49E+OO l .50E-02 2.65E+OI 7.23E-02
Lee l.l2E+OI 3 .07E-02 4 .65E+OI 1.27E-Ol l.66E+OO 4 .53E-03 l.61E+OO 4 .39E-03 9 .12E-Ol 2.49E-03 3.00E+OO 8.20E-03
Leon l .05E+02 2.86E-OI 3 .33E+02 9 .IOE-01 l .59E+OI 4 .36E-02 l.55E+OJ 4 .23E-02 5 .91E+OO 1.61 E-02 2 .72E+OI 7 .43E-02
Liberty 6 .l9E+Ol l.69E-OI l.89E+02 5 .18E-Ol 9.46E+OO 2 .58E-02 9 .17E+OO 2 .51E-02 3.31E+OO 9 .03E-03 l.60E+Ol 4 .37E-02
Limestone 3.l6E+02 8.64E-O I 9.05E+02 2.47E+OO 4 .8 6E+OI l.33E-Ol 4 .72E+Ol l.29E-O I l.53E+Ol 4 .17E-02 8 .12E+OI 2.22E-OI
Lipscomb l .45E+02 3.95E-OI 6.84E+02 l .8 7E+OO 2.12E+OJ 5 .80E-02 2.06E+OJ 5 .63E-02 l.26E+Ol 3.44£-02 4 .02E+Ol I.JOE-OJ
Live Oak 6.56E+OI l.79E-Ol 2 .02E+02 5 .51E-Ol l.OOE+Ol 2 .73E-02 9 .70E +OO 2.65E-02 3.58E+OO 9.77E-03 l .6 7E+Ol 4.58E-02
Loving l .OOE +02 2.74E-Ol 2.93E+02 8.0lE-01 l.54E+Ol 4.22E-02 l.SOE+Ol 4 .09E-02 4 .62E+OO l .26E-02 2.53E+Ol 6.90E-02
6-24
Table 6.11 2008 Annual and OSD County-Level Criteria Pollutant Emission Estimates (Cont.)
~· ~OX-' N~~ .PMur P~i1 :;,%1,r~u-WV' " voe-v~stt~;; & . • /1
CO-ANN CO-OSD NN OSD ANN OSD · OSD SOrANN so::..osn ANN OSD
tons/:vr tons/daY '' ·tons/:vr tons/day -~ tonlllvr tons/day tonlllvr d tons/dav tons/vr tons/dav tons/vr tons/day<
Lubbock l.91E+OO 5.2 lE-03 8.97E+OO 2.45E-02 2.69E-Ol 7.36E-04 2 .61E-Ol 7.14E-04 l.95E-Ol 5 .32E-04 3.99E-Ol l.09E-03
Lynn 6.92E+OO l.89E-02 l.92E+Ol 5 .24E-02 1.07E+OO 2 .93E-03 l.04E+OO 2.84E-03 2.89E-Ol 7 .90E-04 L75E+OO 4.79E-03
Madison l.06E+Ol 2 .89E-02 3 .96E+Ol l.08E-Ol l.59E+OO 4.33£-03 l.54E+OO 4 .20E-03 7.41E-Ol 2 .03E-03 2.84£+00 7 .77E-03
Marion 2 .08£+01 5 .70E-02 6 .64E+Ol 1.81£-01 3 .18E+OO 8 .68E-03 3 .08E+OO 8.42E-03 1.17E+OO 3 .20E-03 5.44E+OO l.49E-02
Martin 5.45E+02 1.49E+OO 1.51E+03 4 .13E+OO 8.45E+Ol 2 .3 1E -OJ 8 .20E+Ol 2 .24E-Ol 2 .28E+Ol 6 .22E-02 l .38E+02 3 .77 E-Ol
Matagorda 9.69E+Ol 2 .65E-Ol 2.72E+02 7.43E-Ol l.49E+Ol 4 .08 E-02 l.45E+Ol 3 .96E-02 4 .55 E+OO l .24E-02 2.48E+OJ 6 .77E-02
Maverick 3 .34E+Ol 9 . l lE-02 1.60E+02 4 .37E-Ol 4 .83E+OO 1 J2E-02 4.68E+OO l .28E-02 3 .12E+OO 8.53E-03 8 .58E+OO 2 .35E-02
McCu ll och 3.16E-02 8 .65E-05 l .49 E-Ol 4.07E-04 4.46£-03 l .22E-05 4.33E-03 l .18E-05 3.23£-03 8.82E-06 6 .62E-03 l.81E-05
McLennan 2 .20E+OO 6.0IE-0 3 7 .53E+OO 2.06E-02 3 .33E-Ol 9 .08E-04 3 .23E-Ol 8 .81E-04 l .37E-Ol 3.75E-04 5 .79E-Ol l .58E-03
McMullen l .20E+02 3.28E-Ol 3 .50E+02 9 .58E-OJ 1.85E+Ol 5.06E-02 1.80E+Ol 4 .91£-02 5.49E+OO l .50E-02 3 .04E+Ol 8 .30E-02
Medina 9 .53E-Ol 2 .60E-03 4.48E+OO l .22E-02 l.34E-Ol 3 .67E-04 l.30E-Ol 3.56E-04 9.72E-02 2.66E-04 l.99E-O I 5.45E-04
Menard 2 .23E+OO 6 .lOE-03 l.05E+Ol 2.87E-02 3.15£-01 8.60E-04 3.05£-01 8.34E-04 2 .28E-Ol 6.22E-04 4 .67E-OI l .28E-03
Midland 4 .01E+02 LlOE+OO l.13E+03 3 .08E+OO 6.21E+Ol UOE-01 6 .02E+Ol l.64E-OI L71E+Ol 4.67E-02 l.02E+02 2 .78E-OI
Milam 2 .llE+OO 5 .76E-03 6 .58E+OO 1.80£-02 3.18E-OI 8 .69E-04 3 .09£-01 8.43£-04 L25E-Ol 3.4 I E-04 5 .07E-Ol l.38E-03
Mitchell 2.03E+OI 5 .54E-02 9 .54E+Ol 2 .61E-Ol 2 .86E+OO 7 .82E-03 2 .78E+OO 7 .58£-03 2 .07E+OO 5 .65£-03 4 .24E+OO l .16E-02
Montague 1.03E+02 2 .81£-01 3 .63E+02 9 .92E-Ol l .56E+Ol 4.26£-02 l.51E+Ol 4.14£-02 6 .16E+OO 1.68£-02 2 .68E+Ol 7 .33E-02
Montgomery 9 .87E+OO 2 .70E-02 3 .05E+Ol 8 .33E-02 l.51E+OO 4 .12E-03 1.46E+OO 3 .99E-03 5 .35E-Ol 1.46E-03 2 .55E+OO 6 .98E-03
Moore 4.49E+OO l.23E-02 2 .14E+Ol 5.85E-02 6 .35E-0 1 1.74E -03 6 .16E-O l 1.68£-03 4 .57E-Ol l.25E-03 9 .77 E -Ol 2.67E-0 3
Motley l.51E+OO 4 . l lE-03 4.48E+OO 1.22E-02 2 .3 lE-01 6 .31E-04 2 .24E-Ol 6.13E-04 7 .2 4E-02 l .98E-04 3 .74£-01 l .02E-03
Nacogdoches 3 .90£+02 1.07£+00 l.15E+03 3 .15£+00 5 .98£+01 1.63E-Ol 5 .80E+O l l.59E-OJ l .97E+Ol 5.39£-02 l.01E+02 2 .75£-01
Nav arro 1.69£+01 4 .63E-02 4 .73E+Ol 1.29£-01 2 .60E+OO 7 . l l E -03 2 .53E+OO 6 .90E-03 8 .06£-01 2.20E-03 4 .26E+OO l .16E-02
Newton 9 .90E+OO 2 .70E-02 3 .83E+O l l.05E-Ol 1.48E+OO 4 .04E-03 l.43E+OO 3 .92E-03 7 .23£-01 l .98 E-03 2 .68E+OO 7 .31E-03
Nolan l.62E+Ol 4.42£-02 6.52E+Ol l.78E-Ol 2.36E+OO 6.45E-03 2 .29E+OO 6 .26£-03 1.31 E+OO 3 .5 8E-0 3 3 .63E+OO 9 .93E-03
Nueces 5 .79 E+Ol l.5 8E-O 1 l.66E+02 4.54 £-01 8 .90£+00 2.43E-0 2 8.63£+00 2 .36£-02 2 .84E+OO 7 .76E-03 l .47E+OI 4 .03E-02
Ochiltree 8 .0lE+Ol 2 . l 9E-O l 3 .07E+02 8.3 8E-Ol 1.21E+Ol 3 .30£-02 1.17£+01 3 .20E-02 5 .31E+OO l .45E-02 2 .13E+Ol 5.83E-02
Oldham 6 .87E+OO l.88E-02 l.90E+Ol 5.20£-02 1.06£+00 2.9 1£-0 3 J.03E+OO 2 .82E-03 2.87E-O l 7 .84£-04 L74E+OO 4 .76E-03
Orange 1.06E+Ol 2 .9 1E-02 4.67E+Ol L27E-Ol J .56E+OO 4 .27£-03 l.52E+OO 4.14E-03 9 .16E-Ol 2.50E-03 2 .94E+OO 8 .02E-03
Palo Pinto l.72E+OI 4 .70E-02 8 .7 1E+OJ 2.3 8 E-O I 2.46£+00 6 .73£-03 2 .39£+00 6 .5 3E-03 l .73E+OO 4 .74£-03 4.40E+OO 1.20£-02
P anola 5 .35E+02 l.46E+OO l .70E+03 4 .6 4£+00 8 .14E+Ol 2 .2 3E-Ol 7.90E+Ol 2.16E-O l 3.00E+Ol 8 .19E-02 1.39£+02 3 .8 1 E -01
Parker 6.86E+Ol l .88 E -Ol 3.40E+02 9.30E-O l 9.9 1E+OO 2 .7 1E-02 9 .62E+OO 2 .63E-02 6 .87 E+OO l.88E-02 l.96E+Ol 5.35E-02
6-25
Table 6.11 2008 Annual and OSD County-Level Criteria Pollutant Emission Estimates (Cont.)
.. "/J,f'X " l•@ +NOx-JSOx-P,M1r PMirrc PMu-PMu-voe-voe-
CO-ANN CO-OSD ANN OSD ANN OSD'' ANN OSD SO...ANN so;...oso ANN OSD, ...
County tons/vr tons/day tons/vr tons/dav ton.Jvr tons/dav ton.Jvr tons/dav tons/vr tons/dav tonslvr tons/dav
Pecos 4 .72E+02 l.29E+OO l.49E+03 4 .06E+OO 7 .23E+Ol l.98E-O l 7.02E+Ol l.92E-O I 2 .39E+Ol 6.54E-02 l.2 1E+02 3.3 1E-Ol
PolJc 3 .25E+Ol 8.88E-02 l.28E+02 3.SOE-01 4.83E+OO l .32E-02 4.69E+OO l .28E-02 2.46E+OO 6 .73E-03 8.69E+OO 2 .37E-02
Potter 6.71E-Ol l.83E-03 3 .16E+OO 8.62E-03 9.47E-02 2 .59E-04 9.18E-02 2.51E-04 6.84E-02 l.87E-04 l.40E-Ol 3.83E-04
Reagan 3.77E+02 l .03E+OO l .05E+03 2.86E+OO 5 .84E+Ol l .59E-Ol 5.66E+Ol l.55E-Ol l.58E+Ol 4 .32E-02 9 .54E+Ol 2.6 1E-Ol
R ea l 9.49E-02 2 .59E-04 4.46E-01 1.22E-03 1.34E-02 3.66E-05 1.30E-02 3 .55 E -05 9.69E-03 2 .65E-05 l.99E-0 2 5.43E-05
Red Ri ver 1.86E+OO 5.09 E-0 3 6 .24E+O O 1.70E -0 2 2 .8 1E-Ol 7 .68E-04 2 .7 3E-Ol 7.45E -04 1.I SE-01 3.14E-04 4.78E-Ol l .3 I E -03
R eeves 7 .84E+OI 2.14E-01 2.96E+02 8 .0 8E-01 l.18E+Ol 3 .22E -02 1.14E+Ol 3.13£-02 5.13 E+OO l.40E-02 2.07E+OI 5 .64E-0 2
Refu g io 6.89E+OI 1.88E-Ol 2.13E+02 5 .81E-01 l.04E+Ol 2 .8 5E-02 1.0IE+O I 2.76E-02 4.00E+OO 1.09E-02 1.66E+O I 4.54E-02
Robe rts 2.29E+02 6.25E-Ol 7 .06E+0 2 l.93E+OO 3 .52E+Ol 9 .61E-02 3.4 1E+Ol 9.32E-02 l.1 2E+Ol 3.07 E -02 5 .88E+O l 1.6 IE-01
Robertson 3 .81E+02 1.04E+OO l .07E+03 2.93E+OO 5.87E+Ol l.60E-01 5.69E+Ol l.56E-Ol l.79E+Ol 4 .89E-02 9 .76E+Ol 2 .67E -01
Runne ls l.23E+Ol 3 .35E-02 5.79E+Ol l.58E-Ol l.73E+OO 4.73E-03 l.68E+O O 4.59E-03 l .25E+OO 3 .41E-03 2 .59E+OO 7 .08E-03
Ru sk 5.94E+02 l.62E+OO l.64E+03 4.48E+OO 9 .16E+Ol 2.SOE-01 8 .88E+Ol 2.43E-O l 2.71E+Ol 7.42E-02 l.52E+02 4 .14E-Ol
Sabine l .2 0E+O O 3 .27E-03 3.llE+OO 8.SOE-03 l.86E-Ol 5.07E-04 l .80E-Ol 4 .92E-04 5 .00E-02 l.37E-04 3 .03 E-Ol 8 .29E-04
San Au!!tistine 3.02E+Ol 8 .24E-02 l.3 I E+02 3.58E-Ol 4.44E+OO l.2 lE-02 4 .30E+OO l .18E-02 2.56E+OO 6 .99E-03 8 .35E+OO 2 .28E-02
San Jacinto 2.1 I E+O l 5.77E-02 5.96E+Ol l .63E-O l 3 .25E+OO 8 .89E-03 3 .16E+OO 8 .62E-03 9.98E-Ol 2 .7 3E-0 3 5.41E+OO l.48E-02
San Patricio 2.19E+Ol 6.00E-02 7 .5 1E+Ol 2 .0SE-01 3.32E+OO 9 .06E-03 3 .22E+OO 8 .79E-03 l.38E+OO 3 .76E-03 5 .74E+OO l .5 7E-0 2
Schleicher 6 .60E+Ol l .80E-O l l .90E+02 5.19E-01 l.02E+O I 2 .7 8E-0 2 9.8 7E+OO 2.70E-0 2 2 .98E+OO 8 .ISE-03 l.66E+Ol 4 .52E-02
Scurry 4 .6 1E+OI 1.26E-01 1.56E+02 4.27E-Ol 7.00E+OO 1.91 E-02 6 .79E+OO 1.85E-02 2.66E+OO 7 .27E -0 3 l.17E+Ol 3 .20E-02
Shackelford 6 .53E+OO 1.78E-02 3.07E+Ol 8.39E-02 9.21E-Ol 2.52E-03 8 .94E-01 2.44E-03 6.66E-Ol l .82E-0 3 1.37E+OO 3 .73E-0 3
Shelby l.50E+02 4 .l l E-01 5 .53E+02 l.51E+OO 2 .26E+OI 6 .17E-02 2 .19E+OI 5.98E-02 l.03E+OI 2 .81E-02 4 .03E+Ol 1.IO E-01
Sherman 2.07E+Ol 5 .67E-02 7.43E+Ol 2 .0 3E-Ol 3 .09E+OO 8.46E-03 3 .00E+OO 8.20E-03 1.39E+OO 3.80E-0 3 4 .87E+OO l.33E-02
Smith 3.09E+O l 8.45E-02 1.15 E+02 3.14E-Ol 4.64E+OO l .27E-02 4 .50E+OO 1.23E-02 2 .15E+O O 5 .86E-0 3 8.29E+OO 2 .26E-02
Somervell 1.12 E+Ol 3.06E-02 5.55E+Ol l.52E-Ol l .62E+OO 4.42 E-03 l .57E+OO 4 .28E-03 l.12E+OO 3.06E-03 3 .19 E+OO 8.72E-03
Starr 2.27E+02 6 .19E-Ol 6 .67E+02 l.82E+OO 3.49E+Ol 9 .54E-02 3 .39E+Ol 9 .26E-02 1.04E+O l 2.84E-02 5 .77E+OI l.5 8E-01
Stephens l .60E+Ol 4 .37E-02 7.58E+Ol 2.07E-Ol 2.26E+OO 6 .l 7E-03 2 .19 E+OO 5 .99E-03 l.63E+OO 4.45E-03 3.43E+OO 9 .37E-03
Sterling 4 .61E+Ol l .26E-Ol l.32E+02 3.6 1E-O l 7 .12E+OO l .95E-02 6 .91E+OO l .89E-02 2.05E+OO 5 .59E-03 l.17E+Ol 3 .18E-02
Stonewall 7 .00E+OO l.91E-02 3 .29E+Ol 8 .99E-02 9.87E-Ol 2 .70E-03 9 .57E-Ol 2 .62E-03 7.14E-O I l.95E-03 1.46E+OO 4 .00E-03
Sutton 3 .03 E+02 8.29E-Ol 8.88E+02 2.43E+OO 4 .6 7E+Ol l .28E -Ol 4 .53E+Ol l.24E-Ol l.41 E+O l 3 .86E-02 7 .58E+O l 2.07E-Ol
Tarrant 5 .97E+02 l.63E+OO 2 .95E+03 8.07 E+OO 8.62E+OI 2.36E-Ol 8 .36E+Ol 2 .29E-Ol 5.95E+Ol l.63E-Ol l .70E+02 4.65E-01
Taylor 2 .50E+OO 6 .84E-0 3 l .20E+Ol 3 .27E-02 3.54E-01 9 .68E-04 3.44E-Ol 9 .39E-04 2 .55E-Ol 6 .96E-04 5.47E-Ol l .SOE-03
6-26
Table 6.11 2008 Annual and OSD County-Level Criteria Pollutant Emission Estimates (Cont.)
,3,. t·r NO"" iK NO~" PMto-PM10-PMu-Wt ,PMu"' .:A: voe-'\,r voe-;> ANN ·,:, C();ANN CO-OSD ANN OSD ANN OSD ANN OSD SOrANN SOr-OSD OSD
?,• County tons/yr tons/dav tons/vr tons/day tons/vr tons/day tons/yr tons/day tons/yr tons/day tons/yr tons/day
Terrell 5.40E+OI l.48E-Ol l .73E+02 4 .72E-Ol 8 .26E+OO 2.26E-02 8 .0IE+OO 2.19E-02 2.83E+OO 7.73E-03 l.38E+Ol 3 .77E-02
Terry l.80E+Ol 4 .93E-02 6.24E+Ol l.71E-Ol 2.74E+OO 7.48E-03 2.66E+OO 7 .26E-03 l.05E+OO 2.88E-03 4.67E+OO l .28E-02
Throckmorton 2.87E+OO 7 .85E-03 l .35E+Ol 3 .69E-02 4 .06E-OI l.l l E-03 3.93E-OI I .07E-03 2.93E-Ol 8.0IE-04 6 .0IE-01 I .64E-03
Titus l .46E-O I 3 .98E-04 6.42E-Ol 1.75E-03 2 .0SE-02 5.61E-05 l.99E-02 5.44E-05 l.49E-02 4.06E-05 3 .0SE-02 8.32E-05
Tom Green 6.3 1E +OO 1.72E-02 2 .50E+Ol 6.84E-02 9.23E-Ol 2 .52E-03 8 .95E-01 2.45E-0 3 4.99E-Ol 1.36E-03 l.42E+OO 3 .89E-03
Trinity 1.30E-01 3 .54E-04 5 .72E-01 l .56E-03 1.83E-02 5.00E-05 1.78E-02 4 .85E-05 l .32E-02 3 .62E-05 2 .71E-02 7.42E-05
Tyler 3 .69E+OI 1.0IE-01 l.58E+02 4 .31E-01 5.43E+OO 1.48E-02 5 .27E+OO 1.44E-02 3 .08E+OO 8.41 E-03 1.0IE+Ol 2 .77E-02
Upshur 4.68E+OI 1.28E-Ol 1.40E+02 3 .83E-01 7 .18E+OO l.96E-02 6.96E+OO l.90E-02 2.42E+OO 6 .60E-03 1.21E+Ol 3.30E-02
Upton 7 .28E+02 1.99E+OO 2 .08E+03 5 .68E+OO 1.13E+02 3 .0SE-01 1.09E+02 2 .98E-Ol 3.19E+OI 8.71E-02 1.85E+02 5 .06E-01
Val Verde 1.1 I E+O l 3 .02E-02 3 .09E+Ol 8.43E-02 1.71E+OO 4.68E-03 l.66E+OO 4 .54E-03 4 .68E-Ol l.28E-03 2.80E+OO 7.65E-03
Van Zandt 5 .53E+OO l.5 lE-02 l.48E+Ol 4.0SE-02 8 .53E-Ol 2.33E-03 8 .28E-Ol 2.26E-03 2.46E-O l 6.73E-04 l .39E+OO 3.79E-03
Victoria 4.30E+OI l.17E-OI l.35E+02 3.68E-Ol 6 .50E+OO l.78E-02 6 .30E+OO l.72E-02 2.51E+OO 6.85E-03 l.05E+Ol 2.88E-02
Walker l .55E-Ol 4 .24E-04 6 .84E-Ol l .87E-03 2.l 9E-02 5.98E-05 2 .12E-02 5 .SOE-05 l.58E-02 4.32E-05 3.24E-02 8 .86E-05
Waller l.26E+Ol 3.46E-02 3 .94E+Ol l.OSE-01 l.92E+OO 5 .23E-03 1.86E+OO 5 .0SE-03 7 .31E-Ol 2.00E-03 3.1 IE+OO 8.SOE -03
Ward 7.63E+Ol 2.0SE-01 3 .34E+02 9 .12E-Ol l.12E+Ol 3.07E-02 1.09E+Ol 2.98E-02 6 .25E+OO l.7 lE-02 1.99E+Ol 5.43E-02
Washington 3.45E+OO 9.43E-03 l.70E+Ol 4 .65E-02 4 .98E-Ol l .36E-03 4 .83E-Ol l .32E-03 3.46E-Ol 9.45E-04 9.71E-Ol 2 .65E-03
Webb 2.85E+02 7.79E-Ol 8.66E+02 2 .37E+OO 4.38E+Ol l.20E-Ol 4 .25E+Ol l .16E-O l l.38E+Ol 3.77E-02 7.26E+Ol l .98E-Ol
Wharton l.04E+02 2.85E-Ol 3.06E+02 8.36E-O l 1.60E+Ol 4.36E-02 l .55E+Ol 4 .23E-02 5 .33E+OO l .46E-02 2.64E+Ol 7.20E-02
Wheeler 6.12E+02 1.67E+OO 1.79E+03 4 .89E+OO 9.45E+Ol 2.58E-Ol 9 .17E+Ol 2 .SOE-01 2 .77E+Ol 7.58E-02 1.56E+02 4 .27E-01
Wichita l.30E+Ol 3.54E-02 5.83E+OI l.59E-Ol l .85E+OO 5 .04E-03 l.79E+OO 4 .89E-03 1.24E+OO 3.39E-03 2 .77E+OO 7.57E-03
Wilbarger 4 .02E+OO 1.1 OE-02 1.89E+OI 5. l 6E-02 5 .67E-Ol l .55E-03 5.SOE-01 l .SOE-03 4 .IO E-01 l.l 2E-03 8.41 E -01 2.30E-03
Willacy 4 .72E+Ol 1.29E-O l l.36E+02 3 .71 E-01 7 .29E+OO 1.99E-02 7 .07E+OO l .93E-02 2.08E+OO 5.69E-03 l .20E+OI 3 .28E-02
Wilson 3.46E-O I 9.45E-04 1.72E+OO 4.69E-03 4.99E-02 l .36E-04 4 .84E-02 l .32E-04 3.46E-02 9.45E-05 9 .86E-02 2.69E-04
Winkler 5 .64E+OI 1.54E-Ol 1.87E+02 5 .IOE-01 8 .61E+OO 2.35E-02 8.35E+OO 2.28E-02 3.07E+OO 8.38E-03 l.46E+Ol 3 .99E-02
Wise l .79E+02 4 .89E-O l 8.44E+02 2 .31E+OO 2.60E+OI 7.l lE-02 2.53E+Ol 6.90E-02 l.69E+Ol 4.61E-02 5 .03E+Ol l.37E-01
Wood 8 .71E+OO 2 .38E-02 2 .95E+OI 8 .07E-02 l .32E+OO 3.60E-03 l .28E+OO 3.49E-03 5.42E-O I l .48E-03 2 .26E+OO 6 .I SE-03
Yoakum 5.71E+OI l.56E-Ol 2.20E+02 6 .0lE-01 8.5 1E+OO 2.33E-02 8.26E+OO 2 .26E-02 4.04E+OO l .lOE-02 1.43E+OI 3 .89E-02
Young 8 .21E+OO 2.24E-02 3.86E+OI l .05E-O l l.16E+OO 3 .16E-03 1.12E+OO 3.07E-03 8 .37E-Ol 2.29E-03 l .72E+OO 4 .69E-03
Zapata 3.43E+02 9.38E-01 1.05E+03 2 .87E+OO 5.28E+Ol l.44E-Ol 5 .12E+OI 1.40E-Ol l.66E+Ol 4.54E-02 8.81E+OI 2.4 1 E-01
Zavala 5 .19E+OO 1.42E-02 2 .71E+Ol 7.41 E-02 7.47E-OI 2 .04E-03 7 .25E-Ol 1.98E-03 5.20E-Ol 1.42E-03 l .44E+OO 3 .94E-03
6-27
7.0 Conclusions and Recommendations
This study presents a comprehensive, statewide 2008 emissions inventory for Texas for
drilling rig engines . This inventory was prepared using well drilling activity data obtained
through permit records from the TRC, combined with emissions data derived through detailed
drilling rig engine data collected through a bottom-up survey effort.
Survey data was collected through a phone and email survey which resulted in the
collection of 45 completed surveys obtained from 39 different drilling rig contractors and/or oil
and gas well operators. These surveys were representative of over 1,500 wells drilled in Texas in
2008 , or about l 0% of all wells drilled in that year, and covered all of the major oil and gas
basins in the state (Andarko , East Texas, Ft. Worth/Bend Arch, Permian, and Western Gulf). The
data collected included drilling rig engine sizes (hp), ages , hours of operation, and model year.
The 2008 inventory was used as the basis for developing 2002 and 2005 year inventories,
as well as projected inventories for 2009 through 2021 . As compared to the previous oil and gas
study prepared by TCEQ in 2007 (for a 2005 base year), the emission estimates presented in this
study reflect a significant decrease in the statewide NOx emission estimate for 2005 (42 ,854 tons
per year in this study compared to 119 ,647 tons per year in the 2007 study). While not as
pronounced, there were also significant decreases in the S02 and CO emission estimates based
on this study. For VOC , PM,0 , and PM2.5, the estimates contained in this study show slightly
higher estimates than in the previous study .
Further improvements to this inventory could be made through the addition of emission
estimates for fracturing operations, as well as additional refinement of the activity data used for
projected years 2009 through 2021.
7-1
8.0 References
ARB, 2001. Speciation Profile Database. Internet address :
http://www.arb.ca.gov/ei /speciate/interoptO 1.htm
Bar-Ilan , Amnon; Friesen, Ron; Pollack, Alison; and Hoats , Abigail , 2007 . WRAP Area Source
Emissions Inventory Projections and Control Strategy Evaluation Phase II. Prepared for the
Western Governor's Association. September, 2007 .
Bar-Ilan, Amnon; Grant, John; Parikh, Rajashi; Pollack, Alison; Henderer, Doug; Pring, Daniel;
and Sgamma, Kathleen , 2008. Development of Baseline 2006 Emissions from Oil and Gas
Activity in the Denver-Julesburg Basin. Prepared for Colorado Department of Public Health and
Environment Air Pollution Control Division. April , 2008.
Bar-Ilan, Amnon; Parikh, Rajashi; Grant, John; Shah, Tejas; and Pollack, Alison, 2008a.
Recommendations for Improvements to the CENRAP States ' Oil and Gas Emissions Inventories .
Prepared for Central States Regional air Partnership. November, 2008
Bar-Ilan, Amnon ; Grant, John; Friesen, Ron and Pollack, Alison , 2009 . Development of Baseline
2006 Emissions from Oil and Gas Activity in the Piceance Basin. Prepared for the Western
Governor's Association and the Independent Petroleum Association of Mountain States . January,
2009 .
Bommer, P , 2008. A Primer of Oilwell Drilling , A Basic Text of Oil and Gas Drilling , Seventh
Edition. The University of Texas at Austin, Petroleum Extension Service. 2008.
Energy Information Administration (EIA), 2009. Supplemental Tables to the Annual Energy
Outlook 2009 , Updated Reference Case with ARRA, Data Tables 113 and 114. Data released
April 2009. Washington , D.C. Internet address:
h tt p ://www .eia.d o e .gov /o iaf/aeo /suppl em ent/stimulus/re gio na larra.htrnl
Pollack, Alison; Russell , James; Grant, John; Friesen, Ron; Fields, Paula; and Wolf, Marty,
2006. Ozone Precursors Emission Inventory for San Juan and Rio Arriba Counties, New Mexico.
Prepared for New Mexico Env ironment Department. August, 2006 .
Russell , James and Pollack, Alison , 2005 . Oil and Gas Emissions Inventories for the We stern
States. Prepared for We stern Governor's Association . December, 2005.
Texas Commission on Environmental Quality (TCEQ), 2007. Emissions from Oil and Gas
Production Facilities , 2007. Prepared by Eastern Research Group, Inc. August 31, 2007.
Texas Commission on Environmental Quality (TCEQ), 2009 . New Oil and Gas SCCs . Data
provided by Greg Lauderdale , TCEQ. June 2, 2009 . Email communication from Greg
Lauderdale, TCEQ to Mike Pring, Eastern Research Group, Inc.
8-1
Texas Commission on Environmental Quality (TCEQ), 2009a. NIF 3.0 Formatting for
TEXAER. Data provided by Greg Lauderdale, TCEQ. June 24, 2009. Email communication
from Greg Lauderdale, TCEQ to Mike Pring, Eastern Research Group, Inc.
Texas Railroad Commission (TRC), 2009a. Summary of Drilling, Completion and Plugging
Reports Processed for 2002. Accessed June 5, 2009. Internet address:
http://www.rrc.state.tx.us/data/drilling/drillingsumma1y/2002/ogdc02an.pdf
Texas Railroad Commission (TRC), 2009b. Summary of Drilling, Completion and Plugging
Reports Processed for 2005. Accessed June 5, 2009 . Internet address:
http ://www.rrc .state.tx.us/data/drilling/dri11ingsummmy/2005 /ogdc05an.pdf
Texas Railroad Commission (TRC), 2009c . Summary of Drilling, Completion and Plugging
Reports Processed for 2008. Accessed June 5, 2009. Internet address :
http://www.rrc.state.tx.us/data/drilling/drillingsummmy/2008 /annual2008.pdf
U.S. EPA, 2005. User 's Guide for the Final NONROAD2005 Model. EPA-420-R-05-013 . U.S.
Environmental Protection Agency, Office of Air and Radiation. December.
U.S. EPA, 2005a . Conversion Factors for Hydrocarbon Emission Components. EPA-420-R-05-
015. U.S. Environmental Protection Agency, Office of Air and Radiation. December.
8-2
Appendix A -Approved Data Collection Plan
5608 Parkcrest Drive , Suite 100
Austin , TX 78731
MEMORANDUM
TO: Greg Lauderdale (TCEQ)
FROM: Rick Baker, Mike Pring (ERG)
DATE: April 3, 2009
SUBJECT: Work Order# 582-7-83985-FY09-01, Deliverable 2b-Final Data Collection Plan
This document serves as the final deliverable for Task 2 of the Work Order, and includes the
results of ERG's review of existing activity and emissions data, and presents a Data Collection
Plan which identifies the proposed approach for collecting the information needed to develop a
comprehensive emissions inventory for land-based drilling rig engines in the state of Texas in
2008. In addition , as described in the Work Plan, we have included our recommendations on how
to proceed with the Texas oil and gas drilling activity emissions estimation project.
The methodology used to develop the 2008 emissions inventory will be based on the 2005
emissions inventory ERG completed for TCEQ in 2007 , but will expand on that effort by
improving the analysis and data collection of both activity data and emissions data. ERG will
conduct the data collection survey as per the proposed Data Collection Plan and as approved by
TCEQ.
1.0 Review of Existing Studies, Data, and Industry Websites
Under Task 2 , ERG has conducted a literature review and evaluated existing information and
studies pertinent to the development of a comprehensive oil and gas drilling activity emissions
inventory for the state of Texas for the year 2008. The results of this research is discussed below
in two parts , the first being a review of existing studies that address estimating emissions from
oil and gas drill rig operations , and the second being the results of our review of existing Texas
data available from government and industry websites and publications.
A-1
1.1 Review of Existing Studies
As mentioned above, the goal of this project is to improve upon the 2005 emissions inventory
ERG completed for TCEQ in 2007 for drill rig engines by obtaining more highly resolved
activity data, as well as more accurate emissions information. Over the last several years,
numerous studies have been conducted in the western states to develop area source emission
estimates for oil and gas sources, with subsequent studies improving upon the data collection
methodology and emission estimation approaches in prior studies. The relevant studies ERG has
identified are provided in Table 1.
Table 1. Existing Drill Rig Engine Studies
Report Geographic Coverage Publication Date
Oil and Gas Emission Inventories for the Western WRAP States December, 2005
States (WRAP Phase I)
Ozone Precursors Emission Inventory for San Juan San Juan and Rio August, 2006
and Rio Arriba Counties , New Mexico Arriba Counties, New
Mexico
Emissions from Oil and Gas Production Facilities Texas August, 2007
WRAP Area Source Emissions Inventory WRAP States September, 2007
Projections and Control Strategy Evaluation Phase
II
Development of Baseline 2006 Emissions from Oil Denver-Julesburg April , 2008
and Gas Activity in the Denver-Julesburg Basin Basin, Colorado
Recommendations for Improvements to the CENRAP States November, 2008
CENRAP States' Oil and Gas Emissions
Inventories
Development of Baseline 2006 Emissions from Oil Piceance Basin, January, 2009
and Gas Activity in the Piceance Basin Colorado
A-2
As a result of a review of the existing literature, ERG has been able to develop a firm
understanding of the types of equipment currently used by industry for different drilling
activities , as well as basic approaches to surveying and compiling emissions estimates. Based on
this review, ERG anticipates organizing our survey based on rig type (drilling rigs vs.
completion/workover rigs), rig engine application (draw works engines , mud pump engines , and
engines for general rig power), whether the rig is mechanical or electrical , well depth, and
wellbore type (vertical, horizontal). Engine size (hp) will also be critical in our analysis , but the .
parameters listed above will dictate the v arious engine sizes we anticipate seeing. For example ,
many workover and completion rigs may be powered by a single engine at less than 600 hp ,
while rigs used on deep (over 15 ,000 feet) horizontal wells may require four or five engines ,
ranging in size from 500 to 1,000 hp each.
In addition to process information , example surveys and survey questions were included in
several studies , and ERG anticipates formulating the survey used for this project utilizing
examples provided in these reports.
It should be noted that these existing studies were comprehensive in nature , inclusive of all
emission sources found at oil and gas exploration and production locations . While well drilling
was included as an emission source , this source category was not a major focus of these efforts .
As such, many of the surveys used in these studies were sent to the oil and gas producers
themselves, and not directly to the owners and operators of the drill rigs , who are typically
contracted by the producers to drill the well. Once a given well is completed, the drilling
contractor will move on to the next well. Therefore, ERG anticipates focusing our survey efforts
on the drilling contractors themselves , with less emphasis on the production companies as has
been done previously.
A-3
Of the reports listed in Table 1, the CENRAP report appears to be the most relevant for this
study as Texas is one of the CENRAP states covered under the report, and the report also
provides "default" activity data and emission factors for the five major oil and gas basins in
Texas (Andarko, East Texas , Fort Worth, Permian, and Western Gulf). While ERG anticipates
developing specific activity data and emissions data from our survey efforts as part of this
project, the CENRAP report may be useful for gap-filling and/or validation depending upon the
results of our survey activities.
1.2 Review of Existing Activity Data
The primary source of activity data to be used to compile the 2008 drill rig emissions inventory
will come from the Texas Railroad Commission (RRC). ERG has contacted the RRC and
obtained a copy of the "Drilling Permit Master and Trailer" database , which contains information
on every application to drill for an oil or gas well in Texas since 1976, including American
Petroleum Institute (API) number, date approved, location (county), wellbore profile, well depth,
spud-in date, and well completion date. ERG is currently in the process of translating this
database into Access for ease of use in estimating emissions. This data will allow us to allocate
emissions spatially (aggregated at the county level), as well as temporally (based on spud-in date
and well completion date for each individual well). Use of this database will result in a more
highly refined dataset than was used in development of the 2005 emissions inventory, which was
based on total depth drilled by county by wellbore type, with drilling times estimated from the
"worst case" well for each county/wellbore-type combination .
In addition, by obtaining the complete dataset, ERG will be able to analyze activity data for
multiple years. As described in the work plan, ERG has concerns regarding the
representativeness of activity data for 2008 given the extreme volatility in the market that year.
Once the data has been properly compiled, ERG will consult with TCEQ and make a final
recommendation as to the base year for this inventory effort. Regardless of which base year is
chosen, the RRC data will be used to backcast the base year inventory to develop the 2002 and
2005 prior year inventories based on drilling permit records for those years. ERG anticipates
developing 2009 through 2021 projected inventories using the base year inventory and
forecasting future activity based on US DOE Energy Information Administration projections of
A-4
oil and gas production for the Southwest and Gulf Coast regions from the Annual Energy
Outlook 2009.
1.3 Review oflndustry Websites
Using information available on the International Association of Drilling Contractors (!ADC)
website, we were able to identify many of the larger drilling contractors in Texas (while there
may be non-IADC members with significant drilling activities in Texas, we did not identify any
during our review). A review of the websites for these larger contractors provided useful
information regarding the drilling rig fleets in use in Texas , and we were able to easily assimilate
a dataset with specific equipment information on over 225 drill rigs . A few examples of this type
of information can be found at the following drill rig operator websites:
a) h ttp ://www.gwdrillin g.co m/servi ces/riglis t.htm
b) http://www.pioneerdrlg .com/HTML/RigF!eet.html
c) http://www .rowancompanie s.com/fw/m ain/Land-Rig-Fleet-61.html
This effort was not exhaustive, and if additional information is needed to gap-fill or supplement
our survey findings , there is additional information that can be obtained online. For example,
Appendix A contains an example "spec sheet" for a specific rig used by Pioneer Drilling,
including specific makes and models of both the draw works engines and mud pump engines.
ERG will compile this information to the extent possible prior to conducting the survey in order
to familiarize ourselves with the engine makes and models we are likely to encounter through the
survey.
2.0 Data Collection Plan
By obtaining and translating the RRC "Drilling Permit Master and Trailer" database , we will
have highly resolved data on all drilling activity that occurred in Texas during the base year. In
addition to wells that were started and finished during the base year, we will also have data on
drilling activities that commenced during the year preceding the base year (but finalized during
the base year), as well as data on wells that were started during the base year but were not
A-5
completed until the following year. Therefore , we feel we have obtained the best activity data
available to use as the basis for the base year inventory.
As we will have obtained the activity data needed to estimate emissions from the RRC database,
the primary focus of our data collection and survey activities will be on obtaining real data from
rig operators who were actively drilling in Texas in 2008 . The goal of this survey will be to
develop a series of "model rig profiles" for different rig types , well depths, and geographic
locations (basin-specific profiles are preferred).
Our proposed survey methodology for obtaining this information is provided below.
2.1 Participant Recruitment
In order to encourage survey response , stakeholder support for the study will be sought. At the
current time , ERG has consulted with contacts at the University of Texas , Southern Methodist
University , the Texas Railroad Commission, and the IADC in an effort to obtain an
understanding of well drilling practices , and to assist us in encouraging stakeholder participation.
The IADC provided helpful information on industry practices , but their organization does not
endorse or participate in any survey activities , so further contribution from them may be limited
to feedback on our draft survey materials and/or survey approach.
In addition to those sources we have already contacted, ERG anticipates encouraging additional
stakeholder participation by contacting the following trade associations and local organizations:
a) Texas Oil and Gas Association (TxOGA)
b) Texas Independent Producers and Royalty Owners Association (TIPRO)
c) Independent Petroleum Association of America (IPAA)
d) Petroleum Equipment Suppliers Association (PESA)
e) The Barnett Shale Energy Education Council (BSEEC)
If possible, ERG will attempt to provide information regarding the study and survey to trade
associations before administering the survey to promote cooperation with the study and to
A-6
identify potential survey participants. We will prepare a draft survey for peer review by members
of the Petroleum Engineering Department at the University of Texas to obtain feedback prior to
implementation. ERG will also request trade associations and stakeholders help distribute a letter
of introduction about the project on TCEQ letterhead to the owners and operators of drill rigs .
2.2 Mail and Phone Surveys
At this point we do not have a specific list of target respondents, but in general , will seek to find
willing participants through our planned communication with the trade groups as described
above, as well as searches through business listings and directories obtained from such sources
as USA Data. Once we have identified a comprehensive listing of likely drilling rig operators,
ERG will obtain the services of a survey contractor to execute this portion of the Data Collection
Plan . ERG will train the survey contractor staff in conducting phone surveys of drill rig
operators , providing background in the purpose of the study and familiarizing staff with industry
terminology they may encounter. Once trained , the survey contractor will initiate the survey , first
by phone calls to targeted respondents, then potentially by follow-up with phone , mail or fax
surveys (as needed). Respondents will be asked to specify their preferred survey response mode,
although phone surveys will be encouraged in order to reduce incomplete responses and errors .
Upon completion of the first week of phone surveys (and at regular intervals thereafter), ERG
will review and audit the results of the phone surveys to confirm that we are contacting
participants willing to provide us the needed information over the phone ( or willing to continue
with the mail survey), and determine if adjustments need to be made to the survey or survey
method in order to ensure sufficient response for proper stratification of our model rig profiles.
The survey itself will focus on collecting the following information for representative, or average
(based on a particular basin or drilling depth), drilling operations:
a) The number of engines on a rig
b) Engine make, model, model year, and size (hp)
c) Average load for each engine
d) Engine function (draw works, mud pumps, power)
A-7
e) Actual engine hour data for well completion (total hours)
f) Actual engine fuel use data for well completion (total fuel use)
g) Engine fuel type (and sulfur content for diesel fuel)
h) Engine-specific emission factors (based on manufacturers ' or vendor data) or actual test
data if available
i) Well location (county, API #)
j) Total well drilling time (actual number of drilling days)
k) Total well completion time (number of days needed for well completion activities)
1) Well depth
Depending on how responsive the survey participant are to the phone survey, and what level of
aggregation they have data available, we may request "average " data for their rigs, or specific
examples based on actual data for specific wells drilled in the base year. ERG will first attempt
to obtain all the required information via the phone survey , but it is expected that specific
information may more readily be obtained by following up with a mail survey.
Appendix B presents an example cover letter that will be included with the mail survey, and
Appendix C provides an example of the types of information that will be requested. ERG will
periodically review the mail survey responses to see if adjustments are needed in order to obtain
a sufficient response rate by checking that all fields/basins are being covered, ensure all wellbore
types are included, and check that the survey adequately covers the range of well depths included
in the RRC drilling permit dataset.
2.3 Field Observations
Once ERG has obtained initial responses to our phone and/or mail surveys and with approval
from the TCEQ project manager, ERG will attempt to obtain permission for site visits to active
drilling sites through survey participation and stakeholder contacts. ERG 's protocol for
conducting on-site visits includes a standardized data collection form, such as that presented in
Appendix D. This form essentially requests the same information as requested during the
phone/mail survey, but adds additional contact information and site visit date. On-site
observations of drill rig engine operation and specifications will be used to verify the data
A-8
collected in the mail and phone surveys , and to attempt to establish equipment load factors and
any other adjustment factors deemed necessary.
Site visits will be coordinated in advance , obtaining the site location, name of contact, and
date/time for each visit. Site contacts will be called one business day in advance to confirm the
time and location for the visit, as well as to determine any site-specific safety or operation
requirements. For example, it is expected that active drilling sites will require steel-toed boots,
hard hat, and safety glasses before entry . ERG representatives will adhere to all company
requirements while on site. If necessary, the TCEQ Project Representative shall obtain an official
letter on TCEQ letterhead explaining the purpose of the study to be presented to site foremen or
other company representatives as requested.
Once on site , each engine will be assigned a unique identifier, and data collection will involve an
inspection of each engine located on site to collect the following information:
a) Make and model , model year, and size
b) A description of how each unit is used (obtained from the site foreman)
c) Typical Fuel usage information (gallons per day over the course of the drilling activity)
d) Typical operating schedule (hours per day over the course of the drilling activity)
e) Typical operating load if available
The on-site data collected will be recorded using the standard reporting form such as that
provided in Appendix D.
ERG will attempt to arrange for visits to multiple locations/fleets for field observations , and will
seek to arrange visits to different types and sizes of rigs, with a preference for a geographical
distribution reflective of the well drilling data obtained from the RRC (as feasible given the
project resources). Preference will be given to companies operating multiple drill rigs in order to
improve data collection efficiency.
A-9
2.4 Confidentiality
Confidentiality will be stressed to participants participating in the study, and will be addressed in
the survey co ver letters and/or phone questionnaire scripts. ERG is particularly sensitive to the
privacy of individuals and businesses. Therefore all interviews and data collection efforts will
begin with a guarantee of privacy, anonymity, and confidentiality. To ensure survey respondent 's
rights to privacy, respondents will be informed of the research purpose , the kinds of questions
that will be asked, and how TCEQ may use the results of the study. Confidentiality will be
maintained by eliminating names from interview records , stripping all respondent-identifying
characteristics from study datasets . In addition, all project staff will be given explicit training
regarding confidentiality protocols and commitments.
3.0 Emissions Calculation Methodology
Once the Data Collection survey is complete, ERG will de velop emission estimates for model rig
fleets which we will then apply to the population of wells from the RRC dataset. It is anticipated
that model rig fleets will be stratified according to:
a) Well location (basin, as identified by County)
b) Well depth (based on RRC data)
c) Well type (v ertical , horizontal)
While these parameters are provided in the RRC dataset, and based on our review of available
literature and operator interviews appear to be the most critical parameters in terms of
differentiating wells for emission estimation purposes, we may encounter other variables that
provide additional distinction between our model rig fleets based on our survey results . For
example, we anticipate the total hp of each rig profile to vary by well depth, and although rig
power information is not provided in the RRC data, it will be critical in estimating emissions.
Once we have compiled the survey data into model rig fleets , an average emissions profile will
be developed for an average well in that fleet. The emissions profile will be developed for each
model rig fleet using a combination of emission and deterioration factors obtained through our
survey, EPA's NONROAD model , and/or AP-42 emission factors. For HAPs , emission factors
will be obtained from the SPECIATE database, and/or AP-42.
A-10
Each well in the RRC dataset will then be assigned to a specific model fleet, and emissions will
be calculated for each well base on scaling emissions from the model fleet to each individual
well based on the ratio of the actual well depth for that well to the model fleet average well
depth. For calculating daily emission estimates (for purposes of ozone-season daily estimates),
the total emissions for each wellbore will be evenly divided by the total number of days between
spud date and completion date, as obtained by the RRC dataset. The end result will be an
estimate of the actual emissions for each well for each day of the drilling period.
4.0 Recommendations
ERG recommends that TCEQ proceed with the drill rig engine emission estimation project as
described above. By obtaining the RRC well permit database in electronic format, the activity
data we now have available provides us with a much greater level of geographical and spatial
resolution for emission estimates than was available when ERG compiled the 2005 oil and gas
emissions inventory. In addition, our literature review has indicated that the "state of the art"
emissions estimation approaches and methodology have continued to be refined over the last few
years as regional, state, and local agencies have become increasingly aware of the magnitude of
emissions from the sources associated with oil and gas exploration and production. Subsequent
studies of emissions from these sources make use of previous studies, and build upon those with
further refinement of the activity and emission factor data used in the estimates. ERG anticipates
being able to continue this evolution for estimating emissions from drill rig engines in Texas.
The next challenge in this process will be to continue to solicit support from stakeholders ,
namely, the trade associations representing oil and gas drill rig operators , as well as the operators
themselves. Through data available on the IADC website, we have obtained contact information
for many of the major drill rig owners and operators in Texas. While we could proceed to contact
them directly at this point, we feel it will be beneficial to the ultimate success of this project to
obtain the endorsement and support from the industry as a whole through the trade associations if
possible.
A-11
APPENDIX A
EXAMPLE OF DRILLING RIG INFORMATION AVAILABLE ONLINE
A-12
APPENDIXB
ADVANCED LETTER TO DRILL RIG OWNERS/OPERATORS ---on TCEQ letter head
(distributed via fax &/or trade associations)
Dear Drill Rig Manager OR <Mr./Ms. LAST NAME>:
The Texas Commission on Environmental Quality (TCEQ) requests your help. We are
asking for your voluntary participation in a study about engines used in the drilling of new and/or
recompleted oil and gas wells in Texas during 2008. The study will involve rig owners sharing
information regarding the operating practices (such as hours of operation) and rig configuration
( such as the number and size of engines) in their fleet. This information will provide a better
understanding of how drilling rig operations are conducted under real-world practices .
TCEQ contracted with Eastern Research Group (ERG), an independent research organization, to
administer this study. We urge you to participate -the results will improve the accuracy of
TCEQ's emissions estimates for drilling rigs across the state.
Prominent trade associations are supporting this study , encouraging their members to pa11icipate,
including the [TxOGA, IPAA. etc ... ] These organizations represent the interests of oil and gas
exploration and production companies at the local , state , and national levels and recognize the
value of the study to industry as well as to government.
Your participation is both voluntary and completely confidential. ERG guarantees the
confidentiality of all participants in this study. This means the information your company
provides will be used for statistical purposes only. Responses will be kept confidential and will
not be disclosed in identifiable form to anyone other than ERG employees or agents without your
consent. Every ERG employee with acces s to identifying information will sign a confidentiality
agreement. This agreement guarantees that we will not disclose ariy information that may
identify you, such as your address, contact information or worksite locations , unless required by
law .
The study involves 3 easy steps.
1. First, the person most knowledgeable about your business ' drilling rig operations will be
asked to participate in a short phone survey about the typical rig configurations and
engine numbers and types used to drill wells in Texas in 2008. In most cases, this survey
will take ten to fifteen minutes.
2. Second, after completion of the phone survey, ERG may send you a written survey
requesting more detailed information about operating practices you employed in drilling
wells in Texas during 2008. In order to minimize the amount of data we are requesting
from any one participant, we would request data for a select number of drilling
operations , most likely requesting information on 2-3 examples for a particular well-
depth, oil field or basin, and well type . However, we would be willing to accept as much
data as made available to us , and can also accept existing data and query it to meet our
A-13
needs if you have existing data that would be helpful , but is not currently in a format
consistent with our survey .
3. Third, after completion of the surveys, ERG may ask for permission to visit one of your
active drilling sites. Pending your approval , an ERG representative will travel to an active
well site and collect information on each engine found on-site. This data includes make,
model, year, load, and engine clock hour readings and fuel usage. Only a small
percentage of companies will be asked to participate in on-site field data collection.
Again, we appreciate your assistance in this important study . If you have any questions , please
call Greg Lauderdale in the Air Quality Division of TCEQ at 512-239-1433. To contact the
independent research firm conducting the study, call the survey project manager, Rick Baker at
512-407-1823, or email him at ri ck. ba ker@ erg .com.
Thank you in advance,
{TCEQ Signature authority}
A-14
APPENDIXC
DRILL RIG SURVEY QUESTIONS
Part 1. General Site Information
1. Name of Company:
2. Well API #:
3. Contact Name:
4. Number of engines on site:
5. Well Type (Vertical, Horizontal):
6. Well Depth:
7. Total Well Drilling Duration (days):
8. Fuel Type (and sulfur content for diesel
fuel)
Part 2. Engine-Specific Information (for each engine)
Engine Use Average Average Average Engine (Drawworks, Make/ Model Engine Operating
ID Mud Pump , Model Year HP Fuel Use Schedule Engine
Power) (gallons) (hours) Load(%)
A-15
APPENDIXD
FIELD DATA COLLECTION FORM
Part 1. General Site Information
1. Name of Company:
2 . Company ID:
3 . Well API #:
4. Site Personnel Contact Name:
5. Site Personnel Title:
6. Site Personnel Phone #:
7. Number of engines on site:
8. Well Type (Vertical, Horizontal)
9. Well Depth:
10 . Total Well Drilling Duration (days):
11. Fuel Type (and sulfur content for diesel
fuel)
12. Date of site visit:
Part 2. Engine -Specific Information (for each engine)
Engine Use Average Average Average
Engine (Draw works , Make/ Model Engine HP Fuel Use Operating Engine
ID Mud Pump , Model Year Schedule Load
Power) (gallons) (hours) (%)
A-16
Appendix B -Survey Letter
EASTERN RESEARCH GROUP , INC .
Dear Owner/Operator:
Eastern Research Group (ERG), an independent research organization, is conducting a study on
drilling rig engine emissions for the State of Texas for calendar year 2008. ERG is conducting
this study with the support of the Texas Independent Producers and Royalty Owners Association
(TIPRO) and the Texas Oil & Gas Association (TXOGA). These organizations represent the
interests of oil and gas exploration and production companies in Texas and recognize the value
of the study to industry as well as to government.
We are asking for your voluntary participation in this study of oil and gas wells that were drilled
in Tex as during 2008. The study will involve sharing information regarding the operating
practices (such as the hours of operation) and rig configuration (such as the number and size of
engines) used during well drilling.
Your participation is voluntary and completely confidential, individual wells do not need to be
identified. The information your company provides will be used for statistical purposes only in
order to develop county-lev el estimates and will not be republished or disseminated for other
purposes. Responses will not be disclosed in identifiable form to anyone other than ERG
employees or agents .
The attached Excel workbook contains our study questions . We are seeking basin specific rig
profiles to complete a typical well in the Andarko, Bend Arch-Fort Worth, East Texas , Permian,
and Western Gulf basins . For each basin, we would like one profile for a vertical well , and a
second profile for a horizontal/directional well. If you operate in multiple basins in Texas , please
complete one worksheet for each basin and well type that you are familiar with. For your
conv enience, the county/basin assignments are included in the workbook in the "Counties by
Basin" worksheet. An example of a completed worksheet is also prov ided . Your expertise is
valued ; please include comments or clarifications!
Your response is requested by June 5, 2009. Completed forms may be submitted via email to Len
Boatman at ll boatman@gm ai l.com , or via fax to 512-579-0315 . For further information or
assistance in completing this form , please call Len Boatman at 512-579-0315.
We appreciate your assistance in this important study. If you have any questions on the study,
please feel free to contact me at (919) 468-7840 , or via email at mike.pring@erg .c om.
Sincerely,
~4
Mike Pring
Senior Environmental Engineer
Eastern Research Group, Inc .
B-1
DRILL RIG SURVEY QUESTIONS
Part 1. General Site Information
Own er/Operator:
Own er/Operator Contact Name:
Own er/Operator Contac t Phone:
Please use county or basin averages for each question .
1. Well Locations ( county or basin)
2. Well Type (vertical, horizontal, directional)
3 . Typical Well Measurement Depth (feet)
4. Typical Well Drilling Duration (days)
5. Typical Number of engines on site
6. Typical Rig Fuel Use (gal/day)
7. Typical Workover/Completion (hours)
8. Typical Workover/Completion Engine Size (HP)
9. Fracing; Yes/No ; Duration (days)
Part 2. Drill Rig Engine-Specific Information (for each engine on a typical rig).
Engine Function Typical Typical Typical Typical Engine Typical Engine Typical Engine (Draw works , Mud Make and Model Engine On-time time under load Load(%) Pump, Power) Model Year Size (HP) (hr/day) (hr/day)
C-1
Appendix D -Survey Data
Table D.1 Survey Data -Horizontal and Directional Wells
# of ,Engine
wells Total Total On-time ,,
covered Make Engine Well Engine (hours/ }
S!Jrvey by Well Engine Engine and Model Size Drilling On-time 1,000 Average
ID survev Well Tvoe Deoth ID Function Model Year (HP) Days (·hours) feet) Load%
(All) E lectric
D200a 5 Directional 10,150 1 Rig Cat 3512 2006 1192 .5 40 960 94.58 65
(All) Electric
D200a 5 Directional 10,150 2 Rig Cat3512 2006 1192.5 40 960 94 .58 65
(All) E lectric
D200a 5 Directional I 0, 150 3 Rig Cat 3512 2006 1192.5 40 960 94.58 65
Dl 80 5 Horizontal 8,000 1 Drawworks Cat3406 19 85 400 22.5 540 67.50 62.5
Dl80 5 Horizontal 8,0 00 2 Drawworks Cat 3406 1985 400 22.5 540 67.50 62.5
D180 5 Horizontal 8,000 3 Mud Pump Cat 399 1985 1260 22.5 540 67.50 75
Dl80 5 Horizontal 8,000 4 Mud Pump Cat 399 1985 1260 22.5 540 67.50 75
Dl80 5 Horizontal 8,000 5 Generator Cat 3406 400 22 .5 540 67.50 80
D180 5 Horizontal 8,000 6 Generator Cat 3406 400 22 .5 540 67.50 80
Cat
D81 33 Horizontal 9,500 1 Drawworks 3412B 1985 475 13 .5 324 34 .11 25 .5
Cat
D81 33 Horizontal 9,500 2 Drawworks 3412B 1985 475 13.5 162 17.05 25.5
Cat
D 8 1 33 Horizontal 9,500 3 Mud Pump 3508B 2005 950 13.5 162 17 .05 25.8
Cat
D81 33 Horizontal 9,500 4 Mud Pump 3508B 2005 950 13.5 162 17 .05 25 .8
D81 33 Horizontal 9,500 5 Generator Cat 3306 1985 270 13 .5 162 17 .05 60
D-1
Table D.1 Survey Data -Horizontal and Directional Wells (Cont.)
#of Engine
wells Total Total On-time
covered Make Engine Well Engine (hours/
Survey by Well Engine Engine and Model Size Drilling On-time 1,000 Average
ID survey Well Type Depth ID Function Model Year (HP) Days (hours) feet) Load%
D81 33 Horizontal 9 ,500 6 Generator Cat 3306 1985 270 13 .5 162 17 .05 60
(A ll ) Electric
D50a 34 Horizontal 10 ,109 1 Rig Cat 3508 2006 950 16 384 37.99 60
(A ll ) E lectric
D50a 34 Horizontal 10 ,109 2 Rig Cat 3508 2006 950 16 384 37 .99 60
(All ) Electric
Dl 19 20 Horizontal 11,500 l Rig Cat 3512 2006 1192 .5 19 456 39 .65 60
(All) Electric
DI 19 20 Horizontal 11 ,500 2 Rig Cat3512 2006 1192.5 19 456 39 .65 60
D97 9 Horizontal 13,000 1 Orawworks Cat 379 1984 550 45 1080 83.08 40.5
D97 9 Horizontal 13,000 2 Drawworks Cat 379 1984 550 45 1080 83 .08 40.5
D97 9 Horizontal 13,000 3 Mud Pump Cat 3508 1995 900 45 1080 83.08 55.8
097 9 Horizontal 13 ,000 4 Mud Pump Cat 399 1989 1250 45 324 24 .92 55 .8
Detroit
097 9 Horizontal 13,000 5 Generator Series 60 2002 400 45 540 41.54 60
Detroit
097 9 Horizontal 13 ,000 6 Generator Series 60 2002 400 45 540 41.54 60
(A ll) E lectric Cat
D50c 3 Horizontal 14,900 1 Rig 3512C 2006 1478 67 1608 107 .92 40
(All) E lectric Cat
D50c 3 Horizontal 14 ,900 2 Rig 3512C 2006 1478 67 1608 107 .92 40
(All) Electric Cat
D50f 11 Horizontal 17,668 1 Rig 3512C 2006 147 8 72 1728 97.80 40
D-2
Table D.1 Survey Data -Horizontal and Directional Wells (Cont.)
' #of Engine
wells Total Total On-time
covered Make Engine Well Engine (hours/
Survey by Well Engine Engine and Model Size .... Drilling On-time 1,000 Average
l
ID survey Well Type Depth ID Function Model Year (HP) Days 1, (hours) feet) Load%
(All) Electric Cat
D50f 11 Horizontal 17 ,668 2 Rig 3512C 2006 1478 72 1728 97 .80 40
Horizontal/ Detroit
Dla 14 Direclionai 1 A AAA. l Drawworks Series 60 l"'\£\AO A""A "' 504 50.40 49.4 1u ,uuu .LUUO '+ /U .Ll
Horizontal/ Mud Pump# Detroit
Dla 14 Directional 10 ,000 2 1 16V2000 2008 1,205 21 504 50.40 35.5
Horizontal/ Mud Pump# Detroit
Dl a 14 Directional 10,000 3 2 16V2000 2008 1,205 21 504 50.40 35.5
Horizontal/ Drawworks/ Detroit
Dla 14 Directional 10 ,000 4 Swivel Motor Series 60 2008 470 21 504 50.40 49.4
Horizontal/ D etroit
Dla 14 Directional 10 ,000 5 Generator # 1 Series 60 2008 470 21 252 25.20 90
Horizontal/ D etroit
Dla 14 Directional 10,000 6 Generator # 2 Series 60 2008 470 21 252 25 .20 90
Horizontal/ Detroit
Dlb 18 Directional 10 ,000 1 Drawworks Series 60 2008 470 21 504 50.40 49.4
Horizontal/ Mud Pump# Detroit
Dlb 18 Directional 10,000 2 l 16V2000 2008 1,205 21 504 50.40 35.5
Horizontal/ Mud Pump# Detroit
Dlb 18 Directional 10 ,000 3 2 16V2000 2008 1,205 21 504 50.40 35 .5
Horizontal/ Drawworks/ Detroit
Dlb 18 Directional 10 ,000 4 Swivel Motor Series 60 2008 470 21 504 50.40 49.4
Horizontal/ Detroit
Dlb 18 Directional 10,000 5 Generator # 1 Series 60 2008 470 21 252 25 .20 90
Horizontal/ Detroit
Dlb 18 Directional 10 ,000 6 Generator # 2 Series 60 2008 470 21 252 25.20 90
Horizontal/
Dl62a 7 Directiona l 11 ,335 1 Drawworks Cat C-18 2005 600 34 816 71.99 60
D-3
Table D.1 Survey Data -Horizontal and Directional Wells (Cont.)
#of Engine
wells Total Total On-time
covered Make Engine Well Engine (hours/
Survey by Well Engine Engine and Model Size Drilling On-time 1,000 Average
ID survey Well Type Depth ID Function Model Year (HP) Days (hours) feet) Load%
Horizontal/
Dl62a 7 Directional 11 ,335 2 Drawworks Cat C-18 2005 600 34 816 71.99 60
Horizontal/
Dl62a 7 Directional 11 ,335 3 Mud Pump Cat 3508 2005 1300 34 408 35 .99 80
Horizontal/
Dl62a 7 Directional 11 ,335 4 Mud Pump Cat 3508 2005 1300 34 408 35 .99 80
Horizontal/
D162a 7 Directional 11 ,335 5 Generator Cat C-15 2005 485 34 408 35 .99 60
Horizontal/
D162a 7 Directional 11,335 6 Generator Cat C-15 2005 485 34 408 35 .99 60
Cat D-
S51 10 Horizontal 8,692 1 Drawworks 353 1975 450 17.5 420 48 .32 43
CatD-
S51 10 Horizontal 8,692 2 Drawworks 353 1975 450 17 .5 420 48 .32 43
Cat D
S51 10 Horizontal 8,692 3 Mud Pump 398 1984 825 17.5 210 24.16 66.2
Cat D
S51 10 Hori zontal 8,692 4 Mud Pump 398 1984 825 17.5 210 24 .16 66.2
CatD
S51 10 Horizontal 8,692 5 Generator 3412 1998 450 17.5 210 24 .16 40
CatD
S51 10 Horizontal 8,692 6 Generator 3412 1998 450 17 .5 210 24.16 40
(All) Electric
Dl l l I 9 Horizontal 10,570 l Rig Cat3512 2006 1476 19 456 43.14 50
(All) Electric
Dll 119 Horiz ontal 10,570 2 Rig Cat3512 2006 1476 19 456 43 .14 50
D-4
Table D.2 Survey Data -Vertical Wells<= 7,000 feet
J Engine
Total Total On-time
# of wells Engine Well Engine (hours/
Survey covered Well Well Engine Engine Make and Model Size Drilling On-time 1,000 Average
ID by survey Type Deoth ID Function Model Year (HP) Days (hours) feet) Load%
D 80 37 Vertical 1,000 1 Drawworks Cummins 1990 450 3 10 30.00 59
D 80 37 Vertical 1,000 2 Mud Pump Cat 343 1985 400 3 10 30 .00 49.4
Drawworks
and Mud Cummins
Dl50 10 Vertical 1,850 1 Pump KT450 1980 500 2.5 10 13 .51 50
D150 10 Vertical 1,850 2 Generator Deutz 1980 50 2.5 10 13.51 20
Draw
D74 48 Vertical 2,200 I Cat3406 1990 470 2 24 21.82 60
Mud pump
D74 48 Vertical 2,200 2 Cat3408 1990 470 2 15 13.64 80
Generator
D74 48 Vertical 2,200 3 25 2 24 21 .82 25
Draw
D51 72 Vertical 2,500 I Cat 3406 1992 425 2 24 19 .20 80
Mud pump
D51 72 Vertical 2,500 2 Cat3406 1992 425 2 24 19 .20 50
Generator John
D51 72 Vertical 2,500 3 Deere 2000 80 2 12 9 .60 20
Cummins
Dl72 6 Vertical 3 ,300 1 Drawworks 400 1985 400 6 .5 24 47 .27 75
Cummins
Dl 72 6 Vertical 3 ,300 2 Mud Pump 400 1985 400 6 .5 24 47.27 75
Perkins 4
Dl72 6 Vertical 3 ,300 3 Generator Cy linder 1995 48 6 .5 24 47.27 77 .5
Draw
D72 41 Vertical 3 ,700 1 Detroit 60 2006 470 10 24 64 .86 65
D-5
Table D.2 Survey Data -Vertical Wells<= 7,000 feet (Cont.)
Engine
Total Total On-time
# of wells Engine Well Engine (hours/
Survey covered Well Well Engine Engine Make and Model Size Drilling On-time 1,000 Average
lD by survey Type Depth ID Function Model Year (HP) Days (hours) feet) Load%
Mud Pump Cummins
D72 41 Vertical 3,700 2 350 2002 350 10 24 64 .86 70
Mud pump Cummins
D72 41 Vertical 3,700 3 350 2002 350 10 24 64 .86 11
Generator
D72 41 Vertical 3,700 4 Cat 3404 2006 280 10 24 64 .86 50
D113 23 Vertical 4 ,200 1 Drawworks Cat 3408 1982 489 6 24 34 .29 52 .65
Dl 13 23 Vertical 4 ,200 2 Mud Pump JD 600 2008 600 6 24 34 .29 73 .9
D113 23 Vertical 4 ,200 3 Generator Cat 3304 1985 97 6 24 34 .29 65
S23 13 Vertical 4,500 1 Mud Pump 1 Cat 353 350 11 24 58 .67 77
Detroit
S23 13 Vertical 4,500 2 Drawworks Series 60 400 11 24 58.67
Detroit
S23 13 Vertical 4 ,500 3 Mud Pump 2 Series 60 330 11 -
John
S23 13 Vertical 4 ,500 4 Generator Deere 80 11 24 58 .67
S3 16 Vertical 4 ,900 I Generator Cat3406 2002 475 11 40 .82 37 .5
S3 16 Vertical 4,900 2 D rawworks Cat 3406 2002 475 11 40 .82 37 .5
Detroit
S3 16 Vertical 4 ,900 3 Mud Pump Series 60 2000 500 11 20.41 75
Detroit
S3 16 Vertical 4 ,900 4 Mud Pump Series 60 2000 500 11 20.41 75
D-6
Table D.2 Survey Data -Vertical Wells<= 7,000 feet (Cont.)
Engine
Total Total On-time
# of wells Engine Well Engine (hours/
Survey covered Well Well Engine Engine Make and Model Size Drilling On-time 1,000 Average
ID by survey Type Depth ID Function Model Year (HP) Days ,, (hours) feet) Load%
Dl 41 14 Vertical 5,000 1 Drawworks Cat 3406 19 88 425 10 24 48 .00 65
Dl41 14 Vertical 5,000 2 Mud Pump Cat 3503 1988 375 10 5 10 .00 67.5
DI41 14 Vertical 5,000 3 Mud Pump Cat3406 1992 425 10 24 48 .00 67.5
Detroit
D141 14 Vertical 5,000 4 Generator Di ese l 1990 250 10 12 24.00 75
DI 519 Vertical 5,000 1 Drawworks Cat C-15 2007 425 5 24.00 49.4
Mud Pump #
DI 519 Vertical 5,000 2 1 Cat C-15 2007 425 5 24.00 35 .5
Mud Pump #
Dl 519 Vertical 5,000 3 2 Cat C-15 2007 425 5 24 .00 35.5
Drawworks/
DI 519 Vertical 5,000 4 Swivel Motor Ca t C-15 2007 425 5 24.00 49.4
Detroit
DI 519 Vertical 5,000 5 Generator Series 60 2007 470 5 24.00 90
Dl 18 25 Vertical 5,000 l Drawworks Cat3408 2005 550 12 24 57.60 27
Detroit
DI 18 25 Vertical 5,000 2 Mud Pump Series 60 2007 550 12 24 57.60 90
Detroit
DJJ 8 25 Vertical 5,000 3 Generator Series 60 2007 350 12 24 57 .60 75
Dl39 14 Vertical 5,200 1 Drawworks Cat 3406B 1993 400 8 24 36 .92 32
D139 14 Ve rtic a l 5,200 2 Drawworks Cat3406B 199 3 400 8 24 36.92 32
D-7
Table D.2 Survey Data -Vertical Wells<= 7,000 feet (Cont.)
Engine
Total Total On-time
# of wells Engine Well Engine (hours/
Survey covered Well Well Engine Engine Make and Model Size Drilling On-time 1,000 Average
ID bv survev Tvne Depth ID Function Model Year (HP) Days (hours) feet) Load%
Dl 39 14 Vertical 5,200 3 Mud Pump Cat 353E 1985 435 8 3 4.62 85
Dl39 14 Vertical 5,200 4 Mud Pump Cat 353E 1985 435 8 24 36 .92 85
DI39 14 Vertical 5 ,200 5 Generator Cat 3306B 1993 400 8 12 18.46 85
DI39 14 Vertical 5 ,200 6 Generator Cat 3306B 1993 400 8 12 18.46 85
Dl63 8 Vertical 6 ,000 1 Drawworks Cat V71 1965 700 10 24 40.00 50
Dl63 8 Vertical 6 ,000 2 Drawworks Cat V7I 1965 700 10 24 40.00 50
Dl63 8 Vertical 6 ,000 3 Mud Pump Cat V379 1975 600 10 24 40.00 75
Dl63 8 Vertical 6,000 4 Mud Pump Cat V379 1975 600 10 24 40.00 75
Dl63 8 Vertical 6,000 5 Generator Cat 3306 19 75 175 IO 24 40 .00 75
(All) Electric D etroit
DI52 4 Vertical 6 ,500 1 Rig Series 60 2008 425 14 24 51.69 70
(A ll ) Electric Detroit
DI52 4 Vertical 6,500 2 Rig Series 60 2008 425 14 24 51.69 70
Detroit
D70 50 Vertical 3,000 l Drawworks 8V-92 1989 475 8.5 24 68 .00 40.4
D70 50 Vertical :,,ooo 2 Mud Pump Cat 3406 1989 425 8 .5 24 68 .00 48.8
John Deer
D70 50 Vertical 3 ,000 3 Generator 4 cylinder 1989 50 8.5 24 68 .00 80
D-8
Table D.3 Survey Data -Vertical Wells> 7,000 Feet
Engine
Total Total On-time
# of wells Make Engine Well Engine (hours/
Survey covered Well Well Engine Engine and Model Size Drilling On-time 1,000 Average
ID by survey Type Depth ID Function Model Year (HP) Davs (hours) feet) Load%
D142 19 Vertical 7,500 1 Drawworks Cat 3406 2005 400 20 480 64.00 34.6
D142 19 Vertical 7,500 2 Drawworks Cat3406 2005 400 20 480 64 .00 34 .6
D142 19 Vertical 7 ,500 3 Mud Pump Cat 3412 2006 650 20 240 32.00 73 .1
D142 19 Vertical 7 ,500 4 Mud Pump Cat C-18 2006 600 20 240 32.00 73 .l
Dl42 19 Vertical 7 ,500 5 Generator Cat3406 2000 400 20 240 32.00 45 .5
D142 19 Vertical 7 ,500 6 Generator Cat 3406 2000 400 20 240 32 .00 45.5
D35 114 Vertical 8,300 1 Drawworks Cat 353 1970 450 12 288 34.70 52.4
D35 114 Vertical 8,300 2 Drawworks Cat 353 1970 450 12 288 34 .70 52.4
D35 114 Vertical 8,300 3 Mud Pump Cat 398 1997 800 12 288 34.70 45 .3
D35 114 Vertical 8 ,300 4 Generator Cat 3408 2000 350 12 144 17 .35 80
D35 114 Vertical 8,300 5 Generator Cat3408 2000 350 12 144 17 .35 80
(All)
Electric
D200 9 Vertical 9,550 l Rig Cat3512 2006 1192 .5 30.5 732 76.65 65
(All)
Electric
D200 9 Vertical 9 ,550 2 Rig Cat3512 2006 1192 .5 30.5 732 76.65 65
D-9
Table D.3 Survey Data -Vertical Wells > 7,000 Feet (Cont.)
Engine
Total Total On-time
# of wells Make Engine Well Engine (hours/
Survey covered Well Well Engine Engine and Model Size Drilling On-time 1,000 Average
ID by survev Type Depth ID Function Model Year (HP) Days (hours) feet) Load%
(A ll )
Electric
D200 9 Vertical 9,550 3 Rig Cat 3512 2006 1192.5 30 .5 732 76 .65 65
D 83 36 Vertical 9 ,750 1 Drawworks Cat C -1 5 2004 475 15.5 186 19.08 45 .3
D 83 36 Vertical 9 ,750 2 Drawworks Cat C-15 2004 475 15.5 186 19 .08 45.3
D83 36 Vertical 9 ,750 3 Mud Pump Cat 398 1975 970 15.5 186 19 .08 52.4
D 83 36 Vertical 9,750 4 Mud Pump Cat 398 1975 970 15 .5 186 19 .08 52.4
D 83 36 Vertical 9 ,750 5 Generator Cat3406 1995 435 15 .5 186 19 .08 80
D83 36 Vertical 9,750 6 Generator Cat 3406 1995 435 15.5 186 19 .08 80
(All)
Electric
Sl2 12 Vertical 10 ,000 1 Rig Cat3512 1192 .5 17 408 40 .8 0 65
(A ll )
E lectric
S12 12 Vertical 10,000 2 Rig Cat3512 1192 .5 17 408 40 .80 65
Cat3408
D 206 2 Vertical 10 ,000 l Drawworks DITA 475 17.5 420 42 .00 24.25
Cat 3408
D206 2 Vertical 10,000 2 Drawworks DITA 475 17 .5 420 42 .00 24.25
Cat
D206 2 Vertical 10,000 3 Mud Pump D399PC 1200 17.5 420 42 .00 24.25
Cat
D206 2 Vertical 10 ,000 4 Mud Pump D399PC 1200 17.5 420 42 .00 24 .25
D-10
Table D.3 Survey Data -Vertical Wells> 7,000 Feet (Cont.)
Engine
Total Total On-time
# of wells Make Engine Well Engine (hours/
Survey covered Well Well Engine Engine and Model Size Drilling On-time 1,000 Average
JD bv survev Tvpe Depth ID Function Model Year ()IP) Davs (hours) feet) Load%
D206 2 Vertical 10 ,000 5 Generator Cat 3406 425 17 .5 210 21.00 100
D206 2 Vertical 10,000 6 Generator Cat3406 425 17 .5 210 21.00 100
D191 3 Vertical 10 ,000 1 Drawworks Cat C-13 2006 410 15 360 36 .00 67 .5
D191 3 Vertical 10,000 2 Drawworks Cat C-13 2006 410 15 360 36 .00 67.5
Dl91 3 Vertical 10,000 3 MudPumo Cat C-15 2006 500 15 360 36 .00 67 .5
D191 3 Vertical 10 ,000 4 Mud Pump Cat C-15 2006 500 15 360 36 .00 67.5
D191 3 Vertical 10,000 5 Generator Cat C-15 2006 500 15 360 36 .00 80
D191 3 Vertical 10,000 6 Generator Cat C-15 2006 500 15 360 36 .00 80
D37 101 Vertical 10,300 l Drawworks Cat 353 1981 450 13 .5 324 31.46 45 .5
D37 101 Vertical 10,300 2 Drawworks Cat 353 1981 450 13.5 324 31.46 45 .5
D37 101 Vertical 10 ,300 3 Mud Pumo Cat 379 1981 550 13 .5 324 31.46 36.9
D37 101 Vertical 10,300 4 Mud Pumo Cat 3 79 1981 550 13 .5 324 31.46 36 .9
D 37 101 Vertical 10,300 5 Generator Cat3406 1995 425 13 .5 162 15 .73 90
D37 101 Vertical 10 ,300 6 Generator Cat3406 1995 425 13.5 162 15 .73 90
D-11
Table D.3 Survey Data -Vertical Wells> 7,000 Feet (Cont.)
Engine
Total Total On-time
# of wells Make Engine Well Engine (hours/
Survey covered Well Well Engine Engine and Model Size Drilling On-time 1,000 Average
ID by survey Type Depth ID Function Model Year (HP) Days (hours) feet) Load%
D1 90 3 Vertical 10 ,500 1 Drawworks Cat C-15 2005 475 30 720 68 .57 67.5
D190 3 Vertical 10,500 2 Drawworks Cat C-15 2005 475 30 720 68 .57 67 .5
D190 3 Vertical 10 ,500 3 Drawworks Cat C-15 2005 475 30 720 68 .57 67 .5
D190 3 Vertical 10 ,500 4 Mud Pump Cat 399 1200 30 720 68 .57 67 .5
D190 3 Vertical 10 ,500 5 Mud Pump Cat 399 1200 30 720 68 .57 67.5
D190 3 Vertical 10 ,500 6 Generator Cat 3412 1000 30 360 34.29 62.5
D190 3 Vertical 10,500 7 Generator Cat 3412 1000 30 360 34.29 62 .5
Dl 21 12 Vertical 10 ,800 1 Drawworks Cat C-15 2004 485 32 .5 7 80 72.22 27 .2
D1 21 12 Vertical 10 ,800 2 Drawworks Cat C-15 2004 485 32 .5 780 72 .22 2 7 .2
Cat
D121 12 Vertical 10 ,800 3 Mud Pump D399TA 2004 1200 32 .5 780 72 .22 35.5
Cat
D121 12 Vertical 10 ,800 4 Mud Pump D399TA 2004 1200 32.5 780 72.22 35 .5
D121 12 Vertical 10,800 5 Generator Cat C-15 2004 485 32.5 390 36.11 35
D121 12 Vertical 10 ,800 6 Generator Cat C-15 2004 485 32 .5 390 36.11 35
D162 8 Vertical 11 ,500 I Drawworks Cat C-18 2005 600 25 600 52.17 60
D-12
Table D.3 Survey Data -Vertical Wells> 7,000 Feet (Cont.)
Engine
Total Total On-time
# of wells Make Engine Well Engine (hours/
Survey covered Well Well Engine Engine and Model Size Drilling On-time 1,000 Average
ID by survev Tvpe Depth ID Function Model Year (HP) Days (hours) feet) Load%
Dl62 8 Vertical 11 ,500 2 Drawworks Cat C-18 2005 600 25 600 52 .17 60
Dl62 8 Vertical 11 ,500 3 Mud Pump Cat 3508 2005 1300 25 300 26.09 80
Dl62 8 Ve1tical 11 ,500 4 Mud Pump Cat 3508 2005 1300 25 300 26.09 80
Dl62 8 Vertical 11 ,500 5 Generator Cat C-15 2005 485 25 300 26.09 60
Dl62 8 Vertical 11 ,500 6 Generator Cat C-15 2005 485 25 300 26.09 60
Detroit
D215 l Vertical 12 ,200 I Mud Pump 2000 200 8 1205 16 384 31.48 60
Detroit
D215 1 Vertical 12 ,200 2 Mud Pump 2000 2008 1205 16 384 31.48 60
Detroit
D215 1 Vertical 12 ,200 3 Drawworks Series 60 2008 470 16 384 31.48 50
Detroit
D215 l Vertical 12 ,200 4 Drawworks Serie s 60 2008 470 16 384 31.48 50
Detroit
D215 1 Vertical 12,200 5 Generator Series 60 2008 470 16 192 15.74 50
Detroit
D215 1 Vertical 12 ,200 6 Generator Series 60 2008 470 16 192 15 .74 50
(All)
Electric Cat
D50b 16 Vertical 12 ,211 l Rig 3512C 2006 1478 21 504 41.27 40
(All)
Electric Cat
D50b 16 Vertical 12 ,211 2 Rig 3512C 2006 1478 21 504 41.27 40
D-13
Table D.3 Survey Data -Vertical Wells> 7,000 Feet (Cont.)
Engine
Total Total On-time
# of wells Make Engine Well Engine (hours/
Survey covered Well Well Engine Engine and Model Size Drilling On-time 1,000 Average
ID by survey Type Depth ID Function Model Year (HP) Davs (hours) feet) Load%
(A ll )
Electric Cat
D50d 6 Vertical 12 ,483 1 Rig 3512C 2006 1478 22 528 42.30 40
(A ll )
E lectric Cat
D50d 6 Vertical 12,483 2 Rig 3512C 2006 147 8 22 528 42 .3 0 40
(All)
E lectric Cat
D50g 9 Vertical 17 ,778 1 Rig 3512C 2006 1478 55 1320 74 .25 40
(All)
Electric Cat
D50g 9 Vertical 17 ,77 8 2 Ri g 3512C 2006 1478 55 1320 74 .2 5 40
(All)
Electric Cat
D50e 10 Vertical 17 ,970 1 Rig 3512C 2006 1478 84 2016 112 .19 40
(All)
E lectric Cat
D50e 10 Vertical 17 ,970 2 Rig 3512C 2006 147 8 84 2016 112 .19 40
D-14
Appendix E -Total Drilling Depth by County by Model Rig Well Type
Category
(see file "TCEQ Drilling Rig Engine Report_Appendices.xls")
Table F.1 Emission Factors for Vertical Wells> 7,000 Feet
Emission Factor Uon/1 ,000 feet\
Pollutant 2002 2005 2008 2009 2010 20JJ 2012 2103 2014 2015 2016 2017 2018 2019 2020 2021
co 2.0?E-01 2 06E-O l l.50E-Ol l.49E-Ol l.49E-Ol l .45E-O l 1.45E-Ol l.l lE-01 l.l lE-01 l.l l E-0 1 l.lO E-01 9 .82E-02 6.44E-02 6.42E-02 6.41E-02 3.55E-02
NOx 4 .61E-O l 4 .60E-O l 4 .15E-Ol 4 .14E-Ol 4 .l lE-01 3.88 E-Ol 3 .88E-O l . 3.62E-Ol 3 .62E-Ol 3 .61E-Ol 3.42 E-Ol 3 .38E-O l 2 .99E-O l 2 .98E-Ol 2 .98E-Ol 2 .52 E-Ol
PMIO 4 03E-02 4 .02E-02 2 .32 E-02 2 .3 2E-02 2 .27E-02 2 .27E-02 2.27E-02 1.3 1 E-02 l .30E-02 l .30E-02 l .27E-02 l.20E-02 8.29E-03 8.27 E-03 8.25E-03 4.3 IE-03
PM2.5 3.9 1E-02 3.90E-02 2 .25E-02 2.25£-02 2 .20E -02 2 .20E-02 2 .20E-02 l.27E-02 l.26E-02 l .26E-02 l .24E-02 l.16E-02 8.04E-03 8.02E-03 8.00E-03 4 .l 8E-03
S02 5.92E-02 5.92E-02 6 .25E-03 6 .25E-03 2 .97E-04 2 .97E -04 2 .97E-04 2 .73 E-04 2 .73E-04 2 .73E-04 2 .73E-04 2 .73E-04 2 .73E-04 2.73E-04 2.73E-04 2 .58E-04
TOG 5.61 E-02 5.59E-02 3 .8 5E-02 3 .85E-02 3.82 E-02 3.74E-02 3 .73E-02 3 .l lE-02 3 .l lE-02 3 .l lE-02 3 . I OE-02 2.82E-02 2 .09E-02 2 .0SE-02 2.0SE-02 l.29E-02
voe 5.52E-02 5.50E-02 3 .79E-02 3 .7 9E-02 3 .76E-02 3 .68 E-02 3 .67E-02 3.0?E-02 3.06E-02 3 .06E-02 3 .05E-02 2 .7 8E-02 2 .05E-02 2 .05E-02 2.05E-02 l .27E-02
F ormal de hvde 8.25E-0 3 8.22E -03 5 .6 7E-03 5.66 E-03 5.62E-03 5 .50 E-03 5.49 E-03 4 .58E-03 4 .58E-03 4 .57E-03 4.56E-03 4.l 5E-03 3 .0 7E-03 3.07E-03 3 .0 6E-03 · l .89E-03
Methanol l .68E-05 l .68E-05 l .16E-05 l .15E-05 l .15E-05 l.12E-05 l .12E-05 9.34E-06 9 .33E-06 9.32E-06 9 .3 1 E-06 8.47E-06 6.26E -0 6 6 .25E-06 6.24E-06 3.86E-06
Benzene l .12E-03 l.12E-03 7 .70E-04 7.69E-04 7.63E-04 7.48E-04 7.46E-04 6 .23E-04 6 .22E-04 6.21E-04 6 .20E-04 5.65E-04 4 .1 7E-04 4 . I 7E -04 4.16E-04 2 .57E-04
Acetaldehvde 4 .12 E-03 4.I IE-03 2 .83E-03 2 .83E-03 2.8 1 E-03 2.75E-03 2 .74E-03 2 .29E-03 2 .29E-03 2 .28E-03 2 .2 8 E-03 2 .0SE-03 I .53E-03 I .53E-03 I .53E-03 9.45E-04
Naohthale ne 5.05E-05 5.03E-05 3.47E-05 3.46E-05 3.44E-05 3.36E-05 3.36E-05 2 .SOE-05 2.SOE-05 2 .SOE-0 5 2.79E-05 2 .54E-05 I .88E-05 l.88E-05 l .87E-05 l.16E-05
o-xvlene 1.91E-04 1.90E-04 I.3 I E-04 I.3 I E-04 l.30E-04 l.27E-04 l .27E-04 l.06E-04 l.06E-04 l.06E -04 l .05E-04 9 .60E-05 7.IO E-05 7.0SE-0 5 7.0?E-05 4 .37E-05
C ume ne l.12 E-0 5 l.1 2E-05 7.?0E-06 7.69E-06 7 .63E-06 7 .4 8E-0 6 7 .4 6E-06 6 .23E-06 6.22E-06 6.2 1E-06 6 .20E-0 6 5.65E-06 4.17E-06 4 .l ?E-06 4.16E-06 2.57E -0 6
Eth v lbenze ne l .74E-04 l.73E-04 l.l 9E-04 l. I 9E-04 l.lSE-04 l.1 6E-04 l.1 6E-04 9 .66E-05 9 .64E-05 9 .63E-05 9 .62E-05 8.75E-05 6.47E -05 6 .46E-05 6.45E -0 5 3.99E-05
Stvrene 3.36E-05 3.35E-05 2 .3 IE-05 2 .3 1E-05 2 .29E-05 2 .2 4E-05 2.24E-05 l .8 7E-05 l .87E-05 l .86E-05 l.86E-05 l.69E-05 l .25E-05 l.25E-05 l .25E-05 7 .72E-06
o-xvlene 5.6 1E-05 5.59E-05 3.85E-05 3 .85E-05 3.82E-0 5 3 .74E-05 3 .7 3E-05 3.l l E-05 3.l lE-05 3.l lE-05 3.I OE-05 2 .8 2E-05 2.09E-05 2.0SE -05 2 .0SE-05 l .29E-0 5
1,3-but ad iene l.O?E-04 l .06E-04 7 .32E-05 7 .3 IE-05 7 .25E-05 7 .IOE-05 7 .09E-05 5 .92 E-05 5 .9 1E-05 5.90E-05 5.89 E-05 5.36E-05 3.97E-05 3.96 E-05 3.95 E-05 2.44E-05
m-xvlene 3.42E-04 3.41E-04 2.35E-04 2.35E-04 2.33E-04 2.28E-04 2.28E-04 l.90E-04 l.90E-04 l .89E-04 l .89 E-04 l.72E-04 I .27E-04 l.27E-04 l .27E-04 7.85E-05
Toluene 8.24E-04 8 .21E-04 5 .66E-04 5.65E-04 5.61E-04 5.49E-04 5.49E-04 4 .58E-04 4 .57E-04 4 .57E-04 4 .56 E-04 4.15E-04 3.0 7E-04 3 .06E-04 3.06 E-04 l .89E-04
n-hexane 8.97E-05 8.94E-0 5 6 .16E-05 6 .15E-05 6 .l l E-05 5.98E-05 5.97E-05 4 .9 8E-05 4 .9 8E-05 4 .97E -05 4 .96E-05 4.52E-05 3.34E-05 3.33 E-05 3.33E-05 2.06E-05
Prooionaldehyde 5 .44E-04 5.42E-04 3 .74 E-04 3.73E-04 3 .?0E-04 3.63E-04 3.62E-04 3 .02 E-04 3.02E-04 3.01 E-04 3 .0 1 E-04 2 .74E-04 2 .02E-04 2.02E-04 2 .02E-04 l.25E -04
2,2 ,4-
trimethylpentane I .68E-04 l .68E -04 l .16E -04 l.15 E-04 l.1 5E -04 I. l 2E-04 l .12E -04 9.34E-05 9.33E -0 5 9 .32E-05 9 .3 1 E-05 8 .47E-05 6 .26E-05 6 .25 E-0 5 6 .24E-05 3 .86E-05
Lead l .69E-06 l .69E-06 9 .74 E-07 9.73 E-07 9 .52E-07 9 .55 E-0 7 9.53E-07 5.49E-07 5.47E-07 5.46E-07 5 .35E-0 7 5 .04E-0 7 3.48E-07 3.47E-0 7 3.46E-0 7 l .8 1E-0 7
Manganese 1.61E-06 l.61E-06 9 .2 8E-07 9.26E-07 9 .06E-07 9 .09E-07 9.07E-07 5 .22E-07 5.21 E-07 5.20£-07 5.IOE-07 4 .80E-07 3 .32E-07 3.3 IE-07 3 .30£-07 l.73E-07
Mercurv l.2 1E-06 1.21E-06 6.96E-07 6.95E-07 6 .8 0E-07 6 .8 2E-07 6 .81E-07 3.92E-07 3 .91 E-07 3.90E-07 3.8 2E-07 3 .60E-07 2.49E-07 2.48E-07 2.47£-07 l .29E-07
Nickel 7.66E-07 7.64E-07 4.4 1 E-07 4.40E-07 4 .3 1E-07 4 .32E-07 4 .3 IE-07 2.4 8E-07 2 .4 8E-07 2.47E-07 2.42E-07 2 .28E-07 l.5 8E-07 l .57E-07 1.57£-07 8.19E-08
An timony l.45E-06 l .45E-06 8 .35E-07 8.34E-07 8 .16E-07 8.18E-07 8. I 7E-07 4 .70E-07 4 .69E-07 4.68E -07 4.59E-07 4.32E-07 2 .98E-07 2 .98E-07 2 .97E-07 l.55 E-0 7
Arsenic 2.02E-07 2 .01 E-07 l.16E-07 l.1 6E-07 l.l 3E-07 l.14E-07 1.1 3E-07 6 .53 E-08 6.52E-08 6.50E-08 6 .37E-08 6 .00E-0 8 4.15E-0 8 4 .13E-08 4.12E-0 8 2.16E -08
Cadmium l.6 1E-06 l.61E-06 9 .2 8E-07 9 .26E-07 9.06E-07 9 .09E-07 9.07E-07 5.22E-07 5 .2 1 E-07 5.20E-07 5.I OE -07 4 .80E-07 3.32E-07 3 .3 IE-07 3.30E-07 l.73E-07
F-1
Table F.1 Emission Factors for Vertical Wells> 7,000 Feet (Cont.)
Emission Factor (ton/1 ,000 feet)
Pollutant 2002 2005 2008 2009 2010 2011 2012 2103 2014 2015 2016 2017 2018 2019 2020 2021
Cobalt 4.44E-07 4.42E-07 2.55E-07 2 .55E-07 2 .49E-07 2.50E-07 2.50E -07 l .44E-07 1.4 3E-07 1.43E-07 l.40 E-07 l.32E-07 9.12E-08 9 09E-08 9 .07E-08 4.74E-08
Phosphorous 5.12E-06 5 .IOE-06 2 .95E-06 2.94E-06 2 .88E-06 2 .89E-06 2.88E-06 l .66E-06 1.65E-06 1.65E-06 1.62E-06 l .52E-06 1.05E-06 1.05E-06 1.05E-06 5.48E-07
Selenium 4 .03E-07 4 .02E-07 2 .32E-07 2.32E-07 2.27E-07 2 .27E-07 2.27E-07 l .31E-07 l.30E-07 l.30E-07 l .27E-07 1.20E-07 8.29E-08 8.27E-08 8.25E-08 4 .3 1E-08
C hl orine l .39E-05 l.38E-05 7 .98E-06 7.97E-06 7.80E-06 7.82E-06 7.80E -0 6 4 .49E-06 4.48E-06 4.47E-06 4 .38E-06 4 .13E-06 2 .85E-06 2.84E-06 2 .84E-06 1.48E-06
Table F.2 Emission Factors for Vertical Wells> 7,000 Feet
Emission Factor (ton/1,000 feet)
Pollutant 2002 2005 2008 2009 2010 201J 2012 2103 2014 2015 2016 2017 2018 2019 2020 2021
co 6 .17E -02 4 .13E-02 3.16E-02 3.09E-02 3 .01 E-02 2 .95E-02 2 .93E-02 2 .86E-02 2 .78E-02 2.23E-02 2 .21E-02 I .39E-02 4 .37E-03 4 .2 I E-03 4 .05E-03 3 .9 1 E-03
NOx 2 .2 1E-0 1 l.82E-OI 1.49 E-OI 1.4 7E-O I l.33E-OI l.30E-OI l.12E-01 8.76E -02 8.28E-02 7.46E-02 7.41E-02 6 .20E-02 4 .02E-02 3.97E-02 2 .76E-02 1.36E-02
PMIO 9 .25E-03 6 .68E-03 4.46E-03 4.43E-03 4 .00E-03 3.94E-03 3.68E-03 3 .37E-03 3 .32E-03 2 .66E-03 2.64E-03 1.67E-03 5 .39E-04 5.16E -04 4.94E-04 4 .75E-04
PM2.5 8 .97E-03 6.48E-03 4 .33E-03 4.30E-03 3 .88E-03 3.83E-03 3 .57 E-03 3 .27E-03 3.22E-03 2 .58E-03 2.56E-03 l .62E-03 5.23E-04 5.00E-04 4 .79E-04 4.60E-04
S02 3 .06E-02 3 .06E-02 3.23E-03 3.23E-03 I .53E-04 1.53E-04 l.53E-04 1.53E-04 I .53E-04 I .43E-04 I .43E-04 l .2 8E-04 l.l l E-04 l.l l E-04 l .l lE-04 I.I I E-04
TOG l.43E-02 7.54E-03 6.72E-03 6.63E-03 6.53E-03 6.44E-03 6.39E-03 6.30E-03 6 .2 1E-03 5.85E-03 5 .8 1 E-03 5 .28E-03 4 .68E-03 4.64E-03 4 .6 1 E-03 4 .58E-03
voe 1.4 1 E-02 7.42E-03 6 .62E-03 6.53E-03 6.43E-03 6 .34E-03 6.29E-03 6.20E-03 6 .1 2E-03 5.76E-0 3 5.72E-03 5.20E-03 4 .60E-03 4 .57E-03 4 .53E-03 4.51E-03
Formaldehyde 2.I I E-03 I .I I E-03 9.89E-04 9.75E-04 9 .60E-04 9.48E-04 9 .39E-04 9.26E -04 9 .1 4E-04 8 .60E-04 8.54E-04 7 .77E-04 6 .88E-04 6 .83E-04 6.78E-04 6 .74E-04
Methanol 4.30E-06 2 .26E -06 2 .02E-06 1.99E-06 I .96E-06 l.93E-06 l.92E-06 I .89E -06 I .86E-06 1.75E-06 l .74E-06 I .58E-06 I .40E-06 1.39E-06 l.3 8E-06 I .37E-06
Benzene 2 .87E-04 l .5 1E-04 l .34E-04 l.33E-04 l .31E-04 l .29E-04 1.28E-04 I .26E-04 l .24 E-04 l.1 7E-04 1.1 6E-04 1.06E-04 9 .35E-05 9.28E-05 9 .22E-05 9 .16E-05
Ace ta ld ehyde 1.05E-03 5.54E-04 4.94E-04 4 .87E-04 4 .80E -04 4.74E-04 4 .69E -04 4 .63E-04 4 .57E -04 4 .30E-04 4.27E-04 3.88E-04 3.44 E-04 3.41E-04 3.39E-04 3.37E-04
Naphthalene 1.2 9E-05 6 .78E-06 6 .05E-06 5.97E-06 5.88E-06 5.80E-06 5.75E-06 5 .67E-06 5.59E-06 5.26E-06 5.23E-06 4 .75E-06 4.2 1E-06 4 .18E-06 4 .15E-06 4 .12E-06
o-xylene 4.87E-05 2 .56E-05 2 .29E-05 2 .25E-05 2.22E-05 2 .19E -05 2 . I 7E -05 2 .14E-05 2.1 IE-05 1.99E-05 1.97E-05 I .80E-05 l .59E-05 l .58E-05 1.57E-05 l .56E-05
Cumene 2 .87E-06 1.5 1 E-06 1.34E-06 l.33E-06 1.3 1E-06 I .29E-06 l .28E-06 l.26E-06 l .24E-06 l.l 7E-06 l.16E-06 I .06E-06 9 .35E-07 9.28E -07 9 .22E-07 9 .16E-07
Eth y lb enzene 4 .44E-05 2.34E-05 2 .08E-05 2 .05E-05 2 .02E-05 2 .00E-05 l .98E-05 I .95E-05 I .9 3E-05 l.81E-05 I .80E-05 I .64E -05 l.45E-05 1.44 E-05 1.4 3E-05 1.42E-05
Styrene 8.60E-06 4 .52E-06 4 .03E-06 3 .98E-06 3 .92E-06 3 .87E-06 3 .83E-06 3 .78E-06 3.73E-06 3.5 1 E-06 3.48E-06 3 . l 7E-06 2 .8 1 E-06 2 .78E-06 2 .76E-06 2 .75E-06
p-xy lene I .43E-05 7 .54E-06 6 .72E-06 6 .63E-06 6.53E-06 6.44E-06 6 .39E-06 6 .30E-06 6 .2 1 E-06 5.85E-06 5.8 1E-06 5.28E-06 4 .68E-06 4.64E-06 4 .6 1E-06 4 .58E-06
1,3-butadiene 2.72E-05 1.43E-05 I .28E-05 I .26E-05 1.24E-05 I .22E-05 l.21E-05 l .20E-05 I .18E-05 I.I IE-05 1. IOE -05 I .OOE -05 8.89E-06 8.82E-06 8.75E-06 8.70E-06
m-xy le ne 8.74E-05 4.60E-05 4 . IOE-05 4.04E-05 3 .98E-05 3 .93E-05 3 .89E-05 3.84E-05 3 .79E-05 3 .57E-05 3 .54E-05 3 .22E-05 2 .85E-05 2 .83E-05 2 .8 1E-05 2 .7 9E-05
Tolu ene 2.1 I E-04 1.11 E-04 9 .89E-05 9 .74E-05 9 .60E-05 9.47E-05 9.39E-05 9 .26E-05 9 . I 3E-05 8.60E-05 8.54E -05 7 .76E-05 6.87E-05 6.82E-05 6 .77E-05 6.73E-05
n-hexane 2.29E-05 1.21 E-05 l .08E-05 1.06E-05 l .04E-05 l.03E-05 1.02E-0 5 I.OI E-05 9.94E-06 9.36E-06 9.29E-06 8.45E-06 7.48E-06 7.43E-06 7 .37E-06 7.33E-06
F-2
Table F.2 Emission Factors for Vertical Wells> 7,000 Feet (Cont.)
Emiss ion Fa ctor (ton /1,000 feet)
Pollutant 2002 2005 2008 2009 201 0 20ll 2012 2103 201 4 20 15 20 16 2017 20 18 2019 2020 202 1
Prop ionalde hyde I .39E-04 7.3 lE-05 6.52E-05 6.43E-05 6.33E-05 6.25E-05 6.19E-05 6.l l E-05 6 .03E-05 5.67E-05 5.63E-05 5.12E-05 4 .5 4E-05 4 .SOE-05 4.47E-05 4 .44E-05
2,2 ,4-
tri me thylpentane 4.30E-05 2.26E-05 2.02E -05 l .99E-05 l .96E-05 l .93E-05 l.92E-05 l .89E-05 l .86E-05 l.75E-05 l.74E-05 l .58E-05 l .40E-05 l .39 E-05 l.38E -05 l .37E-05
Lead 3.89E-07 2.8 1E-07 I .88E-07 I .86E -07 l.68E-07 l.66E-07 1.55E-07 I .42E-07 l.39E-07 l.12E -07 l.l l E-07 7 .00E-08 2.26E-08 2. l?E-08 2 .0?E-08 l.99E-08
Ma nganese 3.?0E-07 2.67E-07 l.79E-07 l.77E-07 l .60E-07 l .58E-07 l.47E-07 l.35E-07 l .33E-07 l.O?E-07 l .06E-07 6.66E-08 2.16E-08 2.06E-08 l .97E-08 l.90E-08
Mercury 2 .78E-07 2.00E-07 l .34E-07 l.33E-07 l.20E-07 l.18E-07 l.lOE-07 l.O lE-07 9 .96E-08 7.99E-08 7.9 1E-08 5.00E-08 l .62E -08 l .55E-08 l .48E-08 l.42E-08
Nickel l.76E-07 l .27E-07 8.48E-08 8.4 1E-08 7.60E-08 7.49E-08 6 .99E-08 6.4 1E-08 6.31 E-08 5.06E-08 5.0lE-08 3.16E -08 l .02E-08 9 .80E-09 9.38E-09 9.02E -09
Antimony 3.33E-07 2.40E-07 l .6 1E-07 l .59E-07 l.44E-07 l.42E-07 l .3 2E-07 l.2 1E-07 l .20E-07 9.59E-08 9.SOE-08 6.00E-08 l .94E-08 l.86E-08 l .78E -08 l.7 1E-08
Arse nic 4 .63E-08 3.34E-08 2 .23E-08 2.21 E-08 2.00E-08 l.97E-08 l .84E-08 l .69E-08 l .66E-08 l.33E-08 l .32E-08 8.33E-09 2.69E -09 2.58E-09 2.47E-09 2 .3 7E-09
Cadmium 3.70E-07 2.67E-07 l.79E-07 l.77E-07 l .60E-07 l.58E-07 l.47E-07 l .35E-07 l.33E-07 l .07E-07 l .06E-07 6 .66E-08 2.16E-08 2 .06E-08 I .97E-08 I .90E-08
Cobal t l.02E-07 7.35E-08 4.91E-08 4 .87E-08 4.40E-08 4.34E-08 4 .0SE-08 3.?IE-08 3.6 5E-08 2.93E-08 2.90E-08 I .83E -08 5.93E-09 5.67E-09 5.43E-09 5.22E-09
Phosphoro us l .l?E-06 8.48E-07 5.67E-07 5.62E-07 5.08E-07 5.01 E-07 4.67E-07 4.28E-07 4 .22E-07 3.38E-07 3 .35E-07 2.12E-07 6 .84E-08 6.55E-08 6.27E-08 6.03E-08
Seleni um 9.25E-08 6.68E -08 4.46E-08 4.43E-08 4 .00E-08 3 .94E-08 3.68E-08 3.37E-08 3.32£-08 2.66E-08 2 .64E-08 I .67E-08 5 .39E-09 5.16E-09 4 .94E-09 4.75E-09
Chl orine 3.18E-06 2 .30E-06 l .5 4E-06 l.52E-06 1.38E-06 1.36E-06 l.27E-06 l.16E-06 l.1 4E-06 9.l?E-07 9.0?E-07 5.73E-07 1.85E-07 l.77E-07 I .?OE-07 1.63E-07
Table F .3 Emission Factors for Directional/Horizontal Wells
Emiss ion .Factor (too /1,000 feet}
Pollutant 2002 2005 2008 2009 201 0 2011 2012 2103 201 4 20 15 2016 20 17 2018 2019 2020 2021
co l.27E-O I l .09E-01 7.77E-02 7.75E-02 7.72E-02 6.47E-02 6.45E-02 6.40E-02 6.38E-02 6.36E-02 6.07E-02 2.66E-02 2 .61E-02 2.59E-02 2 .58E-02 I .34E-02
NOx 5.20E-OI 5.22E-O I 4.I I E-01 4 .1 IE-01 4.00E-01 3.55E-0 1 3.37E-OI 2.52E-01 2.49E-01 2.43E-0 1 2 .24E-01 2.0IE-0 1 2.00E-0 1 l.99E-OI l.99E-O I l.SOE-0 1
PMlO 2.43E-02 l.97E-02 l.1 2E-02 l.12E-02 l.06E-02 9.28E-03 9.38E-03 6.75E-03 6 .74E-03 6.75E-03 6.65E-03 3.92E-03 3.90E-03 3.88E-03 3.8 6E-03 2.?0E-03
PM2.5 2.36E-02 1.9 1 E-02 I .09E-02 l.08E-02 l .03E-02 9.00E-03 9 . IOE-03 6.55E-03 6.54E-03 6 .55E-03 6.45E-03 3.8 1 E-03 3.79E-03 3.76E-03 3.74E-03 2 .6 2E-03
S02 7.36E-02 7.36E-02 7.77E-03 7.77E-03 3.69E -04 3.69E-04 3.69E-04 3.00E-04 3.00E-04 3.00E-04 3 .00E-04 2 .83E-04 2 .83E-04 2.83E-04 2.83E-04 2 .76E-04
TOG 3.95E-02 3.5 IE-02 2.25E-02 2 .25E-02 2.l?E-02 l.64E-02 l.53E-02 2.0SE -02 2.06E-02 2.03E-02 2 .00E -02 l.34E-02 l .34E-02 I .33E-02 I .33E-02 1.I I E-02
voe 3.89E-02 3.46E-02 2.22E-02 2 .2 1E-02 2.14E-02 l .62E-02 I .SOE-02 2.0SE-02 2.03E-02 2.00E-02 l.97E-02 l .32E-02 I .32E-02 l.3 1E-02 l .3 I E-02 l.09E-02
Formaldehyde 5.8 1 E-03 5. l?E-03 3.31 E-03 3.30E-03 3 .2 0 E-03 2.42E-03 2.25E-03 3.0?E-03 3.04E-03 2.98E-03 2.95E-03 I .98E-03 l.97E-03 l.96E-03 I .96E-03 l.63E-03
Me th ano l l .18E-05 l.OSE-05 6 .75E-06 6 .74E-06 6.52E-06 4 .93E-06 4.58E-06 6.25E-06 6.19E-06 6.08E-06 6.0 I E-06 4 .03E-06 4 .0lE-06 4 .00E-06 3 .99E -06 3 .33E-06
Benzene 7.90E-04 7.03E-04 4 .SOE-04 4 .49E-04 4 .35E -04 3.29E-04 3.0SE-04 4 . I ?E -04 4.13E -04 4 .06E-04 4 .01 E-04 2.69E-04 2.68E-04 2 .67E-04 2.66E-04 2 .22E-04
Acetaldehyde 2 .90E-03 2 .58E-03 l.65E -03 1.65E-03 1.60E-03 1.2 I E-03 l. I 2E-03 I .53E-03 I .52E-03 l .49E-03 l.47E-03 9.88E-04 9 .84E-04 9 .8 1 E-04 9 .79E-04 8 .16E-04
Nap hthalene 3 .55E-05 3 .16 E-05 2.03E-05 2 .02E-05 1.96 E-05 I .48 E-05 1.37E-05 1.88E-05 l .86E-05 l .83E-05 l .8 0E-05 l .21E-05 I .20E-05 I .20E-05 l .2 0E-05 9.99E-06
F-3
Table F.3 Emission Factors for Directional/Horizontal Wells (Cont.)
Emission Fa ctor (ton /1,000 feet)
Pollutant 2002 2005 2008 2009 2010 2011 2012 2103 2014 2015 2016 2017 2018 2019 2020 2021
o-x ylene l .34E-04 1.1 9E-04 7.66E-05 7.63E-05 7.39E-05 5.59E-05 5. l 9E-05 7 .09E-05 7 .02E-05 6 .90E-05 6.82E -05 4 .57E -05 4 .55E-05 4 .54E-05 4 .53E-05 3 .78E-05
C umene 7 .90E-06 7 03E-06 4 .SOE-06 4.49E-06 4 .35E-06 3.29E-06 3 OSE-06 4 . l 7E-06 4 .13E-06 4 .06E-06 4 .0 l E-06 2.69E-06 2 .68E-06 2 .67E-06 2 .66E-06 2 .22E-06
Ethv lbenzene l .22E-04 l .09E-04 6.98E-OS 6.96E-OS 6 .74E-OS S.09E-05 4 .73E -05 6.46E-OS 6.40E-OS 6 .29E-OS 6 .22E-OS 4 .l 7E-OS 4 . l SE-05 4 .14E-OS 4 .13E-OS 3.44E-OS
Styrene 2.37E-OS 2 .l l E-05 l .3SE-05 l.35E-OS l .30E-OS 9 .86E-06 9 .16E-06 1.2SE-OS l .24E-OS l .22E-05 l.20E -05 8.07E -06 8.03E-06 8.0 1 E-06 7.99E-06 6 .66E-06
p-xy lene 3.9SE-OS 3.5 1 E-05 2 .2SE-OS 2 .25E-OS 2. l 7E-OS l .64E-OS l .53E-OS 2 .08E-OS 2.06E-OS 2 .03E-OS 2.00E-05 l .34E-05 l .34E-05 l.33E-OS l.33E-OS l.l l E-05
1,3-b ut ad iene 7.SOE-05 6.68E-05 4 .28E-05 4 .27E-05 4.13E-05 3 .12E-05 2 .90E-05 3 .96E-05 3.92E-05 3.85E-05 3.8 1E-05 2.55E-05 2 .54E-05 2.54E-05 2 .53E-05 2 .1 1 E-05
m-xylene 2.4 1 E-04 2.14E-04 1.37E-04 l .37E-04 l.33E-04 l .OOE-04 9 .31 E-05 l.27E-04 l .26E-04 l .24E-04 l.22E-04 8.20E-05 8.16E-05 8.14E-05 8 .12E-05 6 .77E-05
Toluene 5.80E-04 5. I 7E-04 3 .31 E-04 3.30E-04 3 .20E-04 2.42E-04 2 .24E-04 3.06E-04 3 .03E-04 2 .98E-04 2.95E-04 l.98E-04 J.97E-04 l .96E-04 J .96E-04 1.63E-04
n-hexa ne 6.32E -05 5.62E-05 3 .60E-05 3.59E-05 3.48E-05 2.63E-05 2.44E-05 3.33E-05 3.30E-05 3.25E-05 3.2 1 E-05 2 .I SE-05 2 .14E-05 2 .14E-05 2.13E-05 l.78E-05
Propio na lde hyde 3.83E-04 3 .4 1E-04 2 .1 8E-04 2.18E-04 2.l lE-04 l .59E-04 l .48E-04 2 .02E-04 2.00E-04 l.97E-04 l.94E-04 l.30E-04 l .30E-04 l .29E-04 l.29E-04 l.08E-04
2,2 ,4-
trimcthy lpcntanc 1.18 E-04 I.OSE -04 6 .75E-05 6.74E-05 6.52E-05 4 .93 E-05 4 .58E-05 6 .25E-OS 6.19E-05 6.08E-05 6 .0 1 E-05 4 .03E-OS 4 .0 1 E-05 4.00E-05 3.99E-05 3.33E-05
Lead l .02E-06 8 .28E-07 4 .7 1E-07 4 .70E-07 4.46E-07 3.90E-07 3 .94E-07 2.84E-07 2.83E -07 2 .84E-07 2 .79E-07 I .65E-07 l .64E-07 l.63E-07 l.62E-07 l.1 4E-07
Manganese 9 .73E-07 7 .89E-07 4.49E-07 4.47E-07 4.25E-07 3.71E-07 3.75E-07 2.70E-07 2 .70E-07 2.70E-07 2 .66E-07 l .57E -07 l .56E-07 l .55E-07 l .54E-07 I .08E-07
Mercurv 7.30E-07 5.9 1 E-07 3.37E-07 3.35E-07 3.19E -07 2 .78E-07 2.8 1E-07 2.03E-07 2.02E-07 2 .03E-07 l .99E-07 I. I 8E-07 1.17E-07 l.16E-07 1.16E -07 8.I IE-08
N icke l 4 .62E-07 3.75E-07 2.13E-07 2.12E-07 2 .02E-07 l.76E-07 l.78E-07 l.28E-07 l .28E-07 l.28E-07 l .26E-07 7.45E-08 7.42E-08 7.37E-08 7 .33E-08 5.14E-08
An timonv 8 .76E-07 7.l OE-07 4.04E-07 4 .02E-07 3.82E-07 3.34E-07 3.38E-07 2.43E-07 2 .43E-07 2.43E-07 2 .39E-07 l.41E-07 l.4 1E-07 l.40E-07 l .39E-07 9.74E-08
Arsenic 1.22E-07 9.86E-08 5.6 1E-08 5.59E-08 5.3 1 E-08 4 .64E-08 4.69E-08 3.38E-08 3 .37E-08 3.38E-08 3.32E-08 l.96E-08 l .95E-08 l .94E-08 l .93E-08 l .35E-08
Cad mium 9.73E-07 7.89E-07 4.49E-07 4.47E-07 4 .25E-07 3.7 1E-07 3 .75E-07 2 .70E-07 2.70E-07 2 .70E-07 2.66E-07 l .57E-07 l .56E-07 l .55E-07 l .54E-07 l .OSE-07
Cobalt 2 .68E-07 2. l 7E -07 l.23E-07 l .23E-07 l .17E-07 l.02E-07 l.03E-07 7 .43E-08 7.4 1E-08 7.43E-08 7.3 1 E-08 4 .32E-08 4 .29E-08 4 .27E-08 4 .24E-08 2.98E-08
Phosnhorous 3.09E-06 2 .SOE-06 l.43E-06 1.42E-06 1.35E-06 I. I 8E-06 1.19E-06 8.57E-07 8.56E-07 8.58E-07 8.44E-07 4.98E-07 4 .96E-07 4 .93E-07 4 .90E-07 3 .44E-07
Selenium 2.43E-07 1.97E-07 l.1 2E-07 I. I 2E-07 I .06E-07 9.28E-08 9 .38E-08 6 .75E-08 6 .74E-08 6 . 75E-08 6 .65E-08 3 .92E-08 3 .90E-08 3.88E-08 3.86E-08 2.70E-08
Chl ori ne 8.37E-06 6 .78E-06 3.86E-06 3 .85E-06 3 .65E-06 3.19E-06 3 .23E-06 2.32E-06 2.32E-06 2 .32E-06 2.29E-06 l.35E-06 I .34E-06 I .33E-06 1.33E-06 9.3 1 E-07
F-4
Appendix G -Annual and OSD County-Level Emission Estimates
(Criteria Pollutants and HAPs, 2002, 2005, 2008-2021)
(see file "TCEQ Drilling Rig Engine Report_Appendices.xls")
TOTAL
Infrared Imaging SEP -Part I
Draft Work Plan
TOT AL Petrochemicals, Inc.
TOT AL Refinery
Port Arthur, Texas
Prepared by:
Sage Environmental Consulting, LP
July 2007
SAGE
ENVIRONMENTAL CONSULTING
"Fri endly Service, No Surprises!"
TABLE OF CONTENTS
Section 1 Introduction and Background ............................................................................................. 1-l
Section 2 Project Resources .................................................................. Error! Bookmark not defined.
2.1 Project Team ................................................................................................................... 2-1
2.2 Training ............................................................................. Error! Bookmark not defined.
2.3 Equipment ......................................................................... Error! Bookmark not defined.
2.2 . l Task 1 -Prep aration and Training ....................... Error! Bookmark not defined.
2.2.2 Task 2 -Part I oflnfrared Imaging SEP .............. Error! Bookmark not defined.
2.2 .3 Task 3 -Part II oflnfrared Imaging SEP ............. Error! Bookmark not defined.
2 .2.4 Task 4 -Infrared Imaging SEP Report ................ Error! Bookmark not defined.
Section 3 Part I : Imaging Plan .............................................................. Error! Bookmark not defined.
3.1 Imaging Every Regulated Component... ........................... Error! Bookmark not defined.
3.2 Method 21 Monitoring .................................................................................................... 3-3
3.3 Part I Schedule ................................................................................................................ 3-3
Section 4 Preliminary Part II Work Plan ........................................................................................... .4-4
Section 5 Reporting and Documentation ............................................................................................ 5-1
LIST OF APPENDICES
Consent Decree Scope of Work
Sage LDAR Qualifications Statement
FLIR ThermaCAM® GasFindIR Camera
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Additional M21 Monitoring Via Unit Schedule Coordination
Alternate Monitoring Plans
Sage En vironmental Co ns ulting
J uly 2007
i TOTA L Petrochemicals, In c.
TOTA L Infrared Imag ing Part I Work Plan Draft Intern al Vers ion
SECTION 1
INTRODUCTION AND BACKGROUND
TOTAL Petrochemicals , Inc. (TOTAL) has negotiated a Consent Decree with the US
EPA/DOJ . One element of that Consent Decree is to implement a Supplemental
Environmental Project titled "Passive, Infrared Imaging of Refinery Equipment and
Components and Follow-Up Actions" (Infrared Imaging SEP). This is a work plan
developed by TOT AL and Sage Environmental Consulting, LP (Sage) to describe the
approach planned for the Infrared Imaging SEP .
The scope of work for the Infrared Imaging SEP , as negotiated in the Consent Decree, has
been attached as Appendix A of this work plan. The scope of work is divided into two parts.
Part I involves infrared imaging of every regulated component, except for difficult-to-
monitor and unsafe-to-monitor components. In addition to the imaging work, Method 21
monitoring is required for a total of 1000 components , which should consist of up to 500
components where leaks were detected by infrared imaging and the balance where infrared
imaging did not detect a leak. The Consent Decree requires that Part I be completed within
six months after entry of the Consent Decree. This work plan provides details for the
planned execution of Part I of the Infrared Imaging SEP .
Part II of the Infrared Imaging SEP requires imaging of every component in VOC or HAP
service . The Consent Decree requires that Part II be completed within two years after entry
of the Consent Decree. This work plan provides a preliminary plan for Part II for
completeness , but a final work plan for Part II will be developed at completion of Part I.
The remainder of this document presents the work plan in the following major sections :
• Project resources
o Project team
o Training
o Equipment
• Imaging plan
• Preliminary plan for Part II
• Reporting and documentation.
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SECTION 2
PROJECT RESOURCES
TOT AL has provided for the resources needed to complete the Infrared Imaging SEP Part I
work, including skilled personnel, training, and state-of-the-art equipment.
2.1 Project Team
This subsection presents the personnel selected for the project team. TOT AL has selected
Sage to provide the primary imaging staff to carry out the Infrared Imaging SEP, in
coordination with TOT AL Port Arthur Refinery environmental staff. See Appendix B for
additional details on Sage staff and their LDAR experience . The following personnel and
their roles are planned for this work:
Person
Robert Fisher
Brett Kriley
Scott Muller
David Ranum
Buzz Harris
Vinh Do
Organization
TOT AL Port Arthur
Sage Beaumont
Sage Austin
Sage Austin
Sage Austin
Sage Austin
Role
TOTAL Project Manager
Client Service Manager
Sage President and Agency Liaison
Sage Project Manager and Imaging Leader
Technical Consultant
Imaging Team Member
Brett Kriley will serve as the Client Service Manager for this project. Brett will not be
involved in the daily work on the infrared imaging project, but he will review work products
and plans and be available as a resource to TOTAL to help resolve any problems which
might arise.
Scott Muller, the President of Sage, will act as the Corporate Sponsor for this work. Scott
will also serve as a liaison to TCEQ staff in Austin to encourage their participation and to
shepherd any requests for waivers that might be needed.
David Ranum will serve as the Sage Project Manager and the field leader of the imaging
work. David has worked in the fugitive emissions area since the early 1980s. He has worked
on many bagging projects to measure mass emissions from fugitive leaks, initially to develop
correlation equations and emission factors and, more recently, to demonstrate the detection
limits of optical imaging. He has managed an LDAR program for a gas plant in West
Virginia, and he has consulted on LDAR program development in the US and abroad. He
has conducted well over a hundred LDAR audits, including about 100 Consent Decree audits
for petroleum refineries. He has participated in most public demonstrations of Smart LDAR
including:
~ API funded demonstration of the Sandia fiber laser at a Texas refinery in February
2002;
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;i... HARC/TNRCC funded demonstration of the CO 2 laser at an olefins production plant
in Texas in August 2002 ; and
;i... TCET/TCEQ funded five-camera demonstration at two olefins using facilities in
Texas in January/February 2004 .
In addition, David has assisted with several demonstrations of optical imaging funded by
private companies. Two of these demonstrations were long term tests occurring at refineries
in Texas and lasting from six months to one year.
In addition to his LDAR specific work, he has worked on a variety of environmental
measurement projects , including Fourier Transform Infra-Red (FTIR) open-path and closed-
cell monitoring . His combination of experience with infrared instrumentation and broad
knowledge of LDAR make him an outstanding choice for this work. That choice is furthered
by his associate degree in electronics and a MacGyver-like ability to make field repairs and
keep instrumentation on line and functioning properly.
Graham E. "Buzz" Harris will be a technical consultant for the Infrared Imaging SEP. Buzz
is a Chemical Engineer with 3 7 years experience. He began his career as a process engineer
at the Texaco Port Arthur refinery , not far from the TOTAL site . He began working in the
fugitive emissions area since 197 6 when he joined Radian Corporation. He was a key figure
in the development of EPA Method 21 and the bagging method used to quantify mass
emission rates . He has worked in developing correlation equations, emission factors , and
regulatory support for most Federal LDAR rules. He has consulted on LDAR program
development in the US and abroad . He has conducted well over a hundred LDAR audits ,
including nearly 100 Consent Decree audits for petroleum refineries. He has participated in
nearly every public demonstration of Smart LDAR as well as with 5 demonstrations of
optical imaging funded by private companies. The earliest of these demonstrations occurred
in June 2000 at a refinery in Louisiana. One long term test occurred at a refinery in Texas
over a period of 6 months from late 2003 to mid-2004 . Three more demonstrations occurred
during 2006 , one at a Texas refinery , one at a Texas chemical plant, and one at a Texas site
that included both refinery and chemical plant units in the test.
In summary, Buzz Harris is widely respected as an LDAR expert, and is consistently called
to participate in panels on Smart LDAR at conferences and workshops . He has a strong
background in environmental research and will be able to help guide the Infrared Imaging
SEP to achieve meaningful results.
Vinh Do holds a BS in Chemical Engineering from the University of Texas in Austin. Vinh
worked for Sage as an intern while still at the University and has a year of full time
experience since graduation . Vinh began working with David and Buzz on LDAR audits
shortly after graduation, and he has completed 11 LDAR audits to date . In addition , Vinh
has been working solo to provide quarterly QA checks on the LDAR program at a Midwest
refinery. Vinh has also spent several months onsite at refinery assisting the LDAR program
with a retagging effort. Vinh offers the cost-effectiveness of a relatively junior engineer,
good LDAR experience, and good skills with computers and gadgets (such as the Archos
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video recorder that will be used to record the infrared imaging from this demonstration).
This combination should provide a significant contribution to the success of the Infrared
Imaging SEP.
2.2 Training
The staff planned for the Infrared Imaging SEP is very experienced in LDAR in general and
have participated in many optical imaging demonstrations . David Ranum has extensive
experience in using FTIR as an environmental measurement technique , including open-path
monitoring like fence line surveys. This solid base of experience will be augmented by
specific training on the FLIR ThermaCAM® GasFindIR camera.
An instructor from the Infrared Training Center will come to the TOT AL refinery ( or a
meeting room in the area outside the refinery) to conduct a 5-day Level 1 thermography
training course. The fee for this course is good for up to 15 attendees , so all Sage staff who
could potentially work on this project can be trained, as well as TOT AL staff. TCEQ and
EPA Region VI personnel could also be invited to attend this course if there is excess
capacity. This course will cover the general theory of infrared thermography , but there will
also be time for practical field work as well. Since all attendees will be primarily interested
in imaging fugitive leaks , we should be able to focus more practical time in that area than is ·
normally available when attending the course at a training center.
2.3 Equipment
The primary equipment for the Infrared Imaging SEP will include :
• One FLIR ThermaCAM® GasFindIR camera with accessory lenses;
• Archos video recorder with capacity to record a full day of imaging ;
• TVA-1000B portable analyzer for making Method 21 measurements ; and
• An intrinsically-safe data logger that can hold the master equipment list for a unit and
record time stamps for each regulated component at the time it was imaged.
Sage has purchased the FLIR GasFindIR™ camera that will be used for this project. A FLIR
brochure with specifications for this imager has been attached as Appendix B . This FLIR
camera has been the standard for SmartLDAR work since the TCEQ/HARC multi-camera
shootout in 2004.
An Archos video recorder is supplied along with the FLIR camera. These digital video
recorders (DVR) are available from several manufacturers and with different memory
capacities. The Archos recorder will be used initially and upgraded , if needed, to
accommodate up to 10 hours of video capacity. The DVR files will be downloaded at the
end of each day to the hard drive on a Sage laptop computer and burned to DVD weekly for
backup and archiving .
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Sage owns several intrinsically-safe dataloggers , including two Symbol M-9060 PocketPCs
and four Palm Tungsten e2 personal data assistants (PD As). All of these dataloggers have
the capability to upload an Excel file with the master equipment list (in route order) for a
process unit, which will be followed to assure imaging every regulated component. The
Infrared Imaging SEP may use one of these existing dataloggers or a new intrinsically-safe
datalogger with equivalent capabilities .
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SECTION 3
PART I: IMAGING PLAN
This section will present the detailed plans for conducting the Part I imaging of every
regulated component. The di scussion includes the approach for infrared imaging, for Method
21 measurements , and for scheduling the work.
3.1 Infrared Imaging
Sage plans to comply with the requirements of Part I by following a master component
listing in route sequence through each unit. To demonstrate that each regulated component
has been imaged, we plan to record the output of the infrared camera on an Archos video
recorder and to log the time that each regulated component is imaged. An intrinsically safe
electronic datalogger, such as the Symbol Pocket PC model MC-9060 or Palm Tungsten e2 ,
will be loaded with the master component list for the unit to be imaged. The time s etting on
the datalogger, the GasFindIR camera, and the Archos video recorder will be synchronized
each morning. At the clo se st approach to each regulated component, the camera will hold a
still image for about 3 seconds and a time stamp will be entered into the dat a logger that will
correspond to the time on the Archos v ideo recorder. The records could then be queried for
the image of any regulated component by looking up the date and time it was imaged in the
datalogger files and selecting that date/time on the video records . We may also be able to
add voice recording capability so that the tag number can be read off while the component is
imaged .
This approach will be more time consuming than a general infrared imaging scan, because of
the need to follow the master component list rather than just conducting a general scanning
survey. We have used an e stimated productivity of 1000 components per IO-hour work day
for the Part I work. Approximately two hours out of each work day will be spent on
overhead tasks , including :
j., Warm up and electronic checks on the camera;
~ Daily demonstration of camera sensitivity in accordance with the proposed EPA
Alternate Work Practice;
~ Downloading the master component list for the subject unit to the datalogger ;
~ Travel to the unit , check in, and authorization to work;
~ End of day review of components imaged as leakers with the site LDAR crew to
facilitate repair attempts ;
~ Upload of data from the datalogger and the Archos video recorder
~ Cleaning and minor maintenance on the camera; and
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)., Daily report to refinery staff on components imaged , leaks found and any problems
encountered.
The planned field work to image all regulated components in Part I will require a team of two
people for an estimated 11 weeks. A two person team for imaging is needed for safety and to
relieve eye strain, with one person operating the infrared camera and the other operating the
datalogger at any given time. We anticipate the field team changing roles at least once per
hour to relieve the eye strain from closing one eye and looking through the camera eyepiece
with the other. Safety issues occur when the camera operator moves with limited visibility of
tripping hazards , and the second team member will need to act as a spotter. The planned
effort would spend about 2 days of imaging work per process unit to complete the Part I
requirements. Sage plans to use David Ranum and Vinh Do as the Part I field team . The
team will work 5-day weeks of 10 hours per day, or an estimated 550 labor hours for each
team member.
Best practices for identifying leaks using infrared imaging are still in the developmental
phase . One approach calls for imaging each component three times during a moving survey:
once when approaching the component, once when beside it, and once when moving away
from it. Since the background can have an impact on the ability to image a leak, this
approach allows each component to be imaged from several directions with different
backgrounds , thereby increasing the opportunity to detect a leak if one is present. A side
benefit of this approach is that all components on lines with regulated components will be
imaged during completion of Part I work, including connectors and non-regulated
components. A plot plan of each unit will be marked to indicate .the areas with regulated
components imaged in Part I.
Another emerging best practice for imaging is to pause on each component. The basis of this
approach is that leaks are detected with the infrared imager when the eye detects motion in
the field of view , such as an image like smoke wafting away from a component with the
wind. If the camera operator makes a continuous walking survey or continuously pans from
a fixed position, there is much apparent movement in the field of view that may prevent the
operator from noticing the moving plume from a leak.
Observation points (OP) are another concept that may prove to be a best practice when
infrared imaging becomes the primary leak detection method for a site . The OP concept is
that a series of positions can be defined from which a number of regulated components can
be effectively imaged. The OP locations can be defined by GPS or land-based beacon
coordinates or by grids on a plot plan. The camera operator would proceed to each OP and
image a set of regulated components associated with that OP. The time required to
effectively image the components visible from each OP could be noted as they are set up , and
that time could be used as a QC check for subsequent imaging surveys at that OP.
Sage plans to blend all these potential best practices into our approach for Part I. We will
follow the master equipment list route and imaging each component on the approach, when
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closest, and when moving away. We plan to pause on each regulated component at closest
approach for several seconds to allow the data logger to record a time stamp. We will also
experiment with the concept of observation points by trying to establish a set of OPs for one
process unit.
3.2 Method 21 Monitoring
Part I also requires "concurrent" infrared imaging and Method 21 monitoring for all
components where infrared imaging detects a leak (up to a total of 500). Infrared non-detect
components also need to be monitored to round out to 1000 total components imaged by
infrared and monitored by Method 21 .
Sage plans to perform Method 21 on all accessible infrared-detected leaks and to temporarily
mark each leaking component with fluorescent surveyors' tape. A list of all leaking
components identified during the infrared survey will be compiled each day and sent to the
site LDAR team. The site LDAR team will locate the leaks from the Sage leak list and affix
the site leaker tag and, if feasible, make a first attempt at repair or begin the repair process.
Sage plans to perform Method 21 on imager non-detect components at a rate of about one
component for every 15 minutes of survey time. This approach will spread the Method 21
data for non-detects over a wide area of the regulated components surveyed. More than 1700
imager non-detect components should be monitored in this approach if our estimates of
survey pace are correct, and it should go beyond the Consent Decree required 1000 Method
21 monitoring events for any conceivable case.
3.3 Imaging Schedule
The Consent Decree sets the schedule for Part I work at 6 months after the date of entry.
Sage estimates that Part I work will require 11 weeks of imaging, which is less than half of
the 6 month allowance (24 weeks). The planned survey speed provides some flexibility in
the approach to meeting the Consent Decree deadline . Sage plans to do imaging every other
week, which allows time for the refinery to catch up on repairs. The infrared surveys may
image 5000 regulated components in a week, along with 15,000 connectors on lines with
regulated components. Even if the leak rate is very low (0.1 % for example), 20 leaks might
be found that need to have a first attempt within 5 days and be repaired within 15 days.
Some weeks we might find 50 or even 100 leaks. And those 20 to 100 leaks from the
infrared imaging project will be in addition to the normal leaks being detected by the site
LDAR team. This could put a severe strain on the maintenance group. While the Consent
Decree language does allow the possibility of asking EPA Region 6 for additional time to
make repairs, that might not waive TCEQ repair requirements , and should be considered as a
last resort. Sage plans to initially perform infrared imaging every other week and to adjust
that schedule as necessary to meet the 6 month deadline.
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SECTION 4
PRELIMINARY PART II W O RK PLAN
The Part II work involves imaging every component with potential to leak VOC or HAP
compounds. This work will be done in a similar manner to Part I , except that no master
component route will be followed and no time stamp will be recorded for each component.
The imaging will be done in continuous survey mode with the intent to image each
component during the approach, at closest approach, and while moving away. We will not
attempt to pause on each component, but rather to proceed with a slow continuous survey
unless we see possible indications of a leak . The unit plot plans marked up with the areas
imaged in Part I will be used to guide the Part II survey. Different colored markers will be
used to distinguish Part II coverage and for elevated coverage. A total facility plot plan will
also be used to show off-unit areas imaged in Part II.
David Ranum will continue as the Project Manager for Part II and will be in the field to kick
off the new surveys . Vinh Do will take over the field lead for Part II and a second person
with similar LDAR experience will be selected to assist him.
The productivity for Part II surveys should be significantly higher, and we have assumed
3000 components per day coverage . Unfortunately, there are no precise estimates of the
numbers of non-regulated components . Based on our experience, the total non-regulated
component population might range from 6 to 10 times the number of regulated components.·
This would include connectors and all heavy liquid components , as well as non-conventional
components (sight-glasses, manways, meter bodies, exchanger heads , etc.). In addition, the
tank farms, utilities, and all interconnecting pipe racks will need to be imaged. We roughly
estimate Part II to require 18 weeks for a two-person team to complete, but we would like to
reserve the right to review that estimate after completion of Part I work. This represents
about 3 days per process unit.
There is considerable flexibility in schedule for Part II . Sage wou ld initially plan to perform
imaging on alternate weeks to allow time for repairs. Based on early experience in Part II,
the schedule may be extended even more (within the constraint of completing the work
within two years of entry of the Consent Decree).
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SECTION 5
REPORTING AND DOCUMENTATION
The results of Part I and Part II work will be documented in a report at the conclu sion of Part
II work. The report will include :
~ Detailed description of the Infrared Imaging SEP as implemented;
~ Description of any problems encountered in completing the Infrared Imaging SEP
and the solutions thereto ;
~ Itemized list of all eligible Infrared Imaging SEP costs ;
~ Certification that the Infrared Imaging SEP has been fully implemented pursuant to
the provisions of this Consent Decree;
~ Description of the environmental and public health benefits resulting from the
implementation of the Infrared Imaging SEP, with a quantification of the benefits and
pollutant reductions , if fea s ible ; and
~ Listing of all components for which leaks were imaged with the infrared camera,
along with Method 21 readings for those components.
The report will be drafted within 30 days following completion of Part II imaging work.
Two weeks will be allocated to TOT AL for review and comment on the report. The
comments will be addressed and the report finalized within two weeks to meet the 60-da y
requirement in the Consent Decree .
While the Consent Decree only requires a report at the conclusion of both Parts I and II , Sage
plans to prepare a Part I report for internal use while the work is still fresh . The Part I report
will include all the elements described above as they apply to Part I. This draft report will be
held until the completion of Part II and assembled into the complete SEP report at that time.
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APPENDIX A
CONSENT DECREE SCOPE OF WORK
TOTAL Infrared Imaging Project -SCOPE OF WORK
Consent Decree Requirement
TOT AL shall implement a "Passive, Infrared Imaging of Refinery Equipment and
Components and Follow-Up Actions " project ("Infrared Imaging SEP").
Schedule
Part I -within six months after the Date of Entry* of this Consent Decree
Part II -as soon as practical after the Date of Entry* of this Consent Decree but in no event
more than two years after the Date of Entry.
*Date of entry will be sometime in th e next 3 months; howev er, TOTAL would like to
implement Part I ASAP.
Part I Scope of Work
• TOT AL shall conduct passive , infrared imaging of all Refinery components subject to
the LDAR rules at 40 C.F .R. Part 60, Subpart GGG, Part 61 , Subparts J and V , and
Part 63, Subparts F , H, and CC. This requirement shall not apply to components that
are difficult or unsafe to monitor with the infrared imaging equipment. An estimate
of existing TOTAL components regulated under these programs is provided in Table
1-SAGE
• TOT AL shall monitor, in accordance with Method 21 , at least 1,000 Refinery
components imaged concurrently with such imaging. -TOTAL LDAR Contractor
• The 1,000 components subject to concurrent imaging and Method 21 monitoring,
shall include any component imaged from which the imaging detects emissions , up to
a maximum of 500 such components. The remaining 1,000 components subject to
concurrent imaging and Method 21 monitoring shall consist of components from
which the imaging does not detect emissions , and the number of such components
shall be the greater of (I) 500 , or (2) the difference between 1,000 and the number of
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components imaged from which the imaging detects emissions. -SAGE/TOTAL
LDAR Contractor
• TOTAL shall repair, in accordance with the LDAR requirements, any component
found to be leaking under the standards set by the LDAR regulations and Method 21.
-TOTAL
Part II Scope of Work
• TOT AL shall conduct passive infrared imaging of all Refinery components and
operations not so imaged pursuant to Part I of the Infrared Imaging SEP . -SAGE
EPA Deliverable
• Within 60 days after the date set for completion of Phase II of the Infrared Imaging
SEP, TOTAL shall submit a Infrared Imaging SEP Completion Report. The Infrared
Imaging SEP Completion Report shall contain the following: (i) a detailed
description of the Infrared Imaging SEP as implemented; (ii) a description of any
problems encountered in completing the Infrared Imaging SEP and the solutions
thereto; (iii) an itemized list of all eligible Infrared Imaging SEP costs; (iv) a
certification that the Infrared Imaging SEP has been fully implemented pursuant to
the provisions of this Consent Decree ; and (v) a description of the environmental and
public health benefits resulting from the implementation of the Infrared Imaging SEP,
with a quantification of the benefits and pollutant reductions, if feasible. -SA GE
• Report submission shall be signed by an official with knowledge of the Infrared
Imaging SEP and contains the certification statement set forth -TOTAL :
o "I certify under penalty of law that I have personally examined and am
familiar with the information submitted herein and that I have made a diligent
inquiry of those individuals immediately responsible for obtaining the
information and that to the best of my knowledge and belief, the information
submitted herewith is true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility
of fine and imprisonment."
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EPA Dictated Work Plan for Part I.
• TOT AL must retain the services of an experienced camera operator to conduct this
examination, and TOT AL and EPA must agree that the selected operator is qualified
for the job. TOT AL and EPA shall agree in writing (in advance) on the imaging
camera used for this Project. In conducting Part I of this Project, the camera must be
operated within allowed specifications, ranges of tolerance, and/or conditions
prescribed by the manufacturer and/or operator for proper operation in a petroleum
refinery.
• For any component that a Method 21 examination indicates emissions of volatile
organic compounds at a rate or level greater than the applicable LDAR limit, TOT AL
must comply with all applicable requirements of this Consent Decree and the LDAR
regulations.
• If TOT AL timely and properly completes the steps above, and if TOT AL then
concludes that the components requiring correction or repair cannot be accomplished
on the applicable regulatory or Consent Decree schedule, consistent with regular
operation of the Refinery , then TOT AL may request from EPA Region 6 an extension
in the time allowed to complete the requirement. Such request must be made in
writing and explain with particularity the need for additional time and must provide
for as short a schedule as practicable, consistent with orderly completion of repairs
and operation of the Refinery.
• TOT AL shall give EPA Region 6 at least three weeks advance notice of the date on
which the use of the infrared camera imaging and/or Method 21 monitoring pursuant
to this Project will commence. Consistent with all established Refinery safety
procedures and prerequisites, TOT AL shall allow representatives of EPA Region 6
and NEIC to attend, at any and all times, with the individuals (contractors and/or
employees) conducting preparatory work and/or the camera imaging and LDAR
monitoring required under Part I of this Project.
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EPA Dictated Work Plan for Part II.
• In addition to the camera imaging and monitoring required in Part I above, TOT AL
must examine each Refinery component that contains or can contain volatile organic
compounds ( other than the components subject to the LOAR regulations) with a
passive, infrared imaging camera. TOTAL is not required to examine Refinery
components on a component by component basis, so long as the examination is
conducted by an operator and with a camera that meets the requirements of Part I and
such operator follows suitable procedures for examining the areas to be imaged under
this Part of the Project. Consistent with these terms, TOT AL may examine Refinery
components from selected vantage points that allow areas within the Refinery to be
examined as a whole. TOT AL is not required to number each individual component
while examining Refinery components under Part II of the Project, so long as the
examination is completed in a fashion that allows for effective use of the examination
and any recording of it in performing the work called for by this Consent Decree.
• TOTAL will provide EPA the same notice and opportunity to participate with the
work under Part II of this Project that it provides for the work under Part I.
• TOTAL must eliminate the emissions identified by Part II of this Project unless
either: l) such emissions are allowed by law ; or 2) TOTAL and the United States
agree , in writing, that the elimination of a particular emission source is impracticable
because it is inherent in the proper design, construction, and operation of the
Refinery. Nothing in the Consent Decree, however, bars any other option available to
the United States to eliminate such an emission or emission source.
• Nothing in this Consent Decree is intended to limit or disqualify TOT AL, on the
grounds that information was not discovered and supplied voluntarily, from seeking
to apply EPA 's Audit Policy or any state audit policy to any violations or non-
compliance TOT AL discovers during the course of any inv estigation, audit, or
enhanced monitoring that TOT AL is required to undertake for Part II of this Project.
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Table 1 -TOT AL Regulated Component Count
Unit Part 1
Count*
Crude Unit No . 1 2 ,125
Crude Unit No . 2 1,457
Naphtha HOS/Reformer 3 ,710
Sulfolane (HON) 9 ,223
BTX (HON) 2 ,048
Distillate Hvdrotreater No . 1 786
Distillate Hydrotreater No . 2 1,028
Resid Solvent Extraction 22
FCCU 4,499
Alkylation Unit 3 ,303
Condensate Splitter 2 ,326
Toluene Disproportionation (HON) 2 ,229
Sat Liquids 1,626
Fuel Gas Treater/Amine Unit 334
Sour Gas Recovery Compressors 1,044
Fuel Gas Recovery Compressors 133
lsomerization 1,390
Sour Water Striooe r 116
SRU Complex 59
Refractionation 2 ,339
Jet Treater 253
Cogen 213
Transooration Fuels Blending 449
Tank Farm (HON) 6 ,046
Tank Farm 3,719
Marine Terminal 1,126
Marine Terminal (HON) 619
Truck Loading 262
Total 52,484
*Count in cl udes connectors for HON regulated equipment.
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APPENDIXB
SAGE LDAR QUALIFICATIONS STATEMENT
INTRODUCTION
Sage Environmental Consulting, LP (Sage) is an environmental engineering and consulting
company offering regulatory compliance, permitting, and remediation assistance. The
professional services we provide cross a wide spectrum of environmental programs and media
such as air quality, hazardous and solid waste , water quality, hazardous materials , and petroleum
storage activities. While we offer a broad range of services , our specialty is air permitting and
compliance programs for industry. Air permitting and compliance assistance work comprised
approximately 80 % of our total revenue in the last three years.
At Sage, we believe that every project is an opportunity to earn your trust, based on a quality
product done in a cost effective manner, with friendly service and no surprises. We have a
culture that builds trust and loyalty among employees and clients. Our customers have
confidence in our ability to deliver.
Sage currently has offices in Dallas , Austin, Houston, Midland and Beaumont, Texas as well as
Baton Rouge, Louisiana, Atlanta, Georgia, Washington, D.C., Denver, Colorado, San Francisco ,
California, and Tulsa, Oklahoma. Our experienced personnel have performed work both
nationally and internationally.
Auditing and compliance services offered by Sage Environmental include LDAR compliance
assistance. Sage Environmental personnel are nationally recognized for their work in all facets
of LDAR including auditing, program development, monitoring plan development, mass
emis sion studies , and personnel training .
The remainder of this statement of qualifications for LDAR work includes:
},, A listing of LDAR services provided;
},, A listing of LDAR staff with a brief description of experience ; and
},, Example project summaries.
If you need more specific information, please contact either:
G. E . "Buzz" Harris or David Ranum
(512)773-8556 (512)968-8906
buzz@ sageenvironmental.com davidr@ sageenvironmental.com
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LEAK DETECTION AND REPAIR (LDAR) SERVICES
}> LOAR Program Audits
o Third-party Consent Decree audits
o Third-party HRVOC audits (Texas)
o Custom Audits
• Verification of component inventories
• Spotting monitori ng problems
• Shadow monitoring
• Identification of routing problems
• Report reviews
• Answers to compliance questions .
• Open-end line control
• Proper sample station design
}> Smart LOAR
o Design of optical imag ing demonstrations and special studies
o Mass emission measurement to define sensitivity of optical imaging
o Infrared imaging survey work
o Rule interpretation for Smart LOAR
o Design of hybrid infrared/M21 leak detection programs
}> LOAR Program Enhancements
o Development of an LOAR Compliance Plan
o Identification and Responsibilities of Key Program Personnel
o Management of the LOAR Contractor
o Developing an in-house LOAR Training Program
o Important LOAR QA/QC Procedures
o Key LOAR Program Metrics
}> LOAR Program Development
o Starting an LOAR Program from "scratch "
o Equipment Leak Emission Estimates
o Basic LOAR Program Elements
o Complying with basic reporting requirements
o Valuable Program Enhancements
o LOAR Data Management Systems
o Effective Staffing Techniques
}> Training
o Method 21 (Classroom & Practical)
o LOAR Regulations
o Consent Decree Annual Training
o Refinery Operations
o LOAR Equipment Considerations
o Analyzers
o Monitored components
o Smart LOAR
o How to pass a Regulatory Audit
o Fugitive Emission Estimation
o Quality Assurance/Management Systems
}> Mass Emission Measurement
o Bagging to develop Emission Factors & Correlation Equations
o Bagging to support SmartLDAR demonstrations
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Work Plan
KEY PERSONNEL
Graham E. "Buzz" Harris
Buzz Harris is a Chemical Engineer with 37 years experience in industry and consulting. He
began his career as a process engineer at the Texaco Port Arthur refinery , where he spent six
years rotating through responsibility for all the major refining process categories. He joined
Radian Corporation in 1976, where he worked 29 years before joining Sage in 2005. He has
spent the last 31 years in consulting to the refining and petrochemicals industries. Buzz played a
lead role in the fugitive emission studies that established the monitoring protocol, correlation
equations , and emission factors for refineries and SOCMI facilities . He has been continuously
involved in LDAR equipment leaks issues for 30 years , in projects ranging from bagging,
training , database, regulatory development , and auditing. In recent years, LDAR audits have
become nearly his full-time job, having completed more than 100 LDAR audits over the last five
years . Buzz has also been active in supporting the development of new LDAR technologies,
such as Smart LDAR. He has played a part in most public demonstrations of infrared imaging of
equipment leaks, and has participated in several private demonstrations. Buzz is active in
development and presentation of training materials related to LDAR, and is a lecturer at LDAR
University. He has presented several dozen papers on LDAR at workshops and meetings and has
chaired several LDAR-specific workshops. He is regular participant on expert panels to field
audience questions on LDAR and Smart LDAR.
David Ranum
David has over 28 years experience in a variety of areas within the environmental field. These
areas include instrumentation system design , air toxics monitoring programs, fugitive emission
programs, design and installation of continuous emission monitoring systems (CEMS) and
mobile air monitoring systems, maintenance of infrared air monitoring systems (FTIR) and
numerous projects related to LDAR.
In the LDAR area, David participated in several key bagging projects that eventually led to the
development and enhancement of refinery emission correlation equations. He has initiated
LDAR programs both here and abroad as well as managed a large scale refinery tagging
inventory project. David provides training on a variety of LDAR issues to refinery LDAR staff
and participates in symposiums dealing with topics of interest to the LDAR community. David
currently serves as a member of an LDAR audit team that has conducted LDAR audits at over
100 refinery and petrochemical plants across the U.S. David has served as the audit leader on 16
LDAR audits. David is participating as part of a three-person team of LDAR experts in a
comprehensive assessment of LOAR for a major oil company site.
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Erin Badough
Erin holds a Masters in Environmental Engineering from Texas Tech University and has four
years experience in environmental consulting. Erin has worked on a variety of permitting and
emission inventory projects , in addition to her LDAR work. Erin began working with the LDAR
audit team in 2006 and has completed 13 refinery Consent Decree audits to date. She has
worked in both the compliance/recordkeeping/reporting position and the field
monitoring/tagging/OEL position. Erin has also participated in a bagging study to measure
emission rates to quantify the sensitivity of Smart LDAR applications in petroleum refinery.
Vinh Do
Vinh holds a BS degree in Chemical Engineering from the University of Texas in Austin.
Although a recent graduate, he worked as an intern at Sage prior to graduation, was a co-op at a
petrochemical facility in Texas, and worked in a research position at the University. Since
graduation, he has worked in a number of fields , but has specialized in LDAR auditing. Vinh
has completed 12 LDAR audits to date, including Consent Decree audits of refineries and
HRVOC audits of refinery and chemical facilities in Texas. Vinh has worked on a bagging
project that involved cross-checking the results of Smart LDAR, Method 21, bagging, and the
Hi-Flow™ sampler. Vinh is also the site lead for doing quarterly shadow monitoring for a
Midwest petroleum refinery.
Catherine Barry
Catherine was a zoology major at Texas Tech University who now has about 1.5 years
experience in environmental consulting. She has participated in six LDAR audits, filling both
the office and field roles. Catherine has also been the site lead for a major study to determine
which streams are applicable to LDAR rules at a Texas petrochemicals facility. She worked with
Aspen modelers to take major stream composition data and fit it to the more detailed lines on
piping and instrumentation diagrams. She set up a database to manage the stream data and a
variety of spreadsheets to present the results, including cells that make rule applicability
decisions based on stream composition and header data about the unit.
Kyle Brzymialkiewicz
Kyle is a recent Chemical Engineering graduate from the University of Texas in Austin. Kyle
has split his time between LDAR audits and BWON work. He has completed 4 LDAR audits
and has been trained on both the office (rule compliance/recordkeeping/reporting) and field
(comparative monitoring/component identification/open-ended line/sample systems) work.
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Judah Fontenot
Judah has over 16 years of technical and regulatory experience with a variety of Environmental
air quality issues. Judah managed leak detection and repair (LDAR) programs at several
petroleum refineries and chemical plants, including direct responsibility for technician
monitoring , valve repair (including drill and tap procedures), delay of repair, management of
change, recordkeeping and reporting, compliance auditing and database management. Judah is
based out of the Dexter Field Services Beaumont office. Dexter is an independent company with
the same ownership as Sage. Judah was a Sage employee before Dexter was founded , and he
can be available for Sage projects through subcontract.
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REPRESENTATIVE PROJECT EXPERIENCE
LOAR Auditing
Refinery Consent Decree Audits
The US EPA and DOJ hav e been negotiating Consent Decrees (CD) with the oil companies
operating refineries in the US . All these Consent Decrees include a requirement for an LDAR
audit every two years , and half those audits must be third-party. Sage is the leading provider of
refinery Consent Decree audits , with over 100 completed to date .
The scope of work for Consent Decree audits include s:
~ Performing comparative monitoring ;
~ Reviewing records to ensure monitoring and repairs were completed in the required
periods ;
~ Rev iewing component identification procedures , tagging procedures , and data
management procedures ; and
~ Observing LDAR technicians' calibration and monitoring techniques.
Sage has performed CD LDAR audits that ranged from two people for two days up to four
people for two weeks , depending on the size of the refinery and the depth of comparative
monitoring. A typical audit includes a staff of three people for a week .
After safety orientation, each audit begins with a kickoff meeting to communicate the planned
activities . The work then splits into two parallel tracks: office and field. The office work
includes a detailed review of rule compliance, recordkeeping , and reporting. Several checklists
are used to guide the office review and provide consistency in our audits. One checklist is for
NSPS VY compliance , which both NSPS GGG and Refinery MACT refer to for the detailed
compliance activities. We also use an overall audit checklist to track other inquiries into records
and reports . We try to do as much of the record reviews electronically as possible , using Excel
and Acces to leverage our ability to review thousands of records in the time it would take to
re v iew dozens of paper records.
The field work is built around comparative monitoring , where we will typically select three
process units as subjects . A target monitoring goal is set for each unit based on its size and the
historical claimed leak rate. The component subset is field selected in a semi-random manner,
starting in one comer and monitoring one out of each four components, for example, if the target
were 25%. This approach spreads the components to be monitored ov er the whole unit , which
helps the selected subset to be representative of the overall unit. This approach also involves a
physical survey of the whole unit , which allows component identification, open-ended line
control, and sample systems flushing control to be evaluated. Component identification is
evaluated by trying to justify each component without an LDAR tag as being a utility, a heavy
liquid, a non-monitored component type, or other exempt stream/component. Anomalies in
tagging are reviewed with operations and LDAR staff, and any that appear to have been
overlooked from the LDAR inventory are documented. Each missing cap , plug, or blind is
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evaluated to see if it is in hydrocarbon service and whether or not it is controlled by a double
block valve system; each OEL compliance issue is documented. Sample points are reviewed to
see if they include flushing control by closed-loop, closed-purge, or closed-vent. Any sample
points that do not include flushing control are checked with operators to see if they are routine,
and any uncontrolled routine sample points are documented.
The CD audits also include observation of the site LDAR team. This includes observations of
calibration and review of instrument calibration/certification records. Several technicians are
also observed in the course of monitoring and any repair attempts they are allowed to make.
Sage prepares a spreadsheet with all findings documented before leaving the site. A closing
meeting is held to explain findings and comparative monitoring agreement. Sage has gathered
data from over 100 similar facility audits and developed benchmarks for a number of LDAR
program criteria, including: OEL control, accuracy of component identification, comparative
monitoring agreement, percent of components on delay of repair, percent of valves designated as
difficult to monitor, percent of valves designated unsafe to monitor, and LDAR staffing
levels/effectiveness.
A preliminary report is repaired within two weeks following the field audit. The client reports
back with any challenges to the audit findings, which are generally worked out over a conference
call. Sage then prepares a final audit report saved in a signed/certified Adobe pdf format.
HRVOC Audits
The Texas Commission on Environmental Quality (TCEQ) has adopted special regulations for
the Houston-Galveston area that focus on reducing emissions of highly reactive VOC ( ethylene,
propylene, and butylenes). The HRVOC rules include an annual third-party audit requirement,
which focuses on comparative monitoring to verify site leak rates. The HR VOC audits also
include a review of tagging of leaking equipment, QA/QC analyses of monitoring data, and a
review of calibration records .
Sage typically staffs HRVOC audits with two people for a period of3 to 10 days. The time-
determining factor is the comparative monitoring. The TCEQ sets a minimum number of valves
to be monitored based on valve population and claimed leak rate. The comparative monitoring is
to be done randomly from the set of all HRVOC valves at the facility. Two random selection
schemes have been used: random component selections from the HRVOC master valve list and
random grid selections from a geographic division of process areas. Sage has used both random
selection criteria. The random component selection approach is preferred where the number of
components to be monitored is low and the location/description information in the database is
sufficiently detailed to allow quick location of each component. The random grid approach
works as an alternative when larger numbers of components must be monitored and when
location/description information is not sufficiently detailed to locate individual components in a
reasonable amount of time. HRVOC audits include a closing meeting with all findings at the
conclusion of the audit and quick report generation.
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Specialty LDAR Audits
In addition to conducting complete program audit , Sage provides specialized LOAR audit
assistance. Specialty audits are often driven by the client rather than a regulation. The facility
may have discovered a group of overlooked components, so Sage is hired to take a broader look
at component identification accuracy to check for additional problems . Another common
specialty audit focuses only on monitoring quality, while others might focus only on
recordkeeping issues.
Consent Decree (EPA-DOJ Negotiations)
Sage has assisted several refineries with expert advice on their Consent Decree negotiations, cost
assessments , responses and compliance, in the area of LOAR.
LDAR Program Implementation and Enhancements
Starting a New LDAR Program-Sage staff have helped clients start several LOAR programs
from scratch. One such program was for a gas plant that triggered NSPS KKK. Sage staff have
also helped petroleum refineries in Europe and Asia develop cost-effective LOAR programs.
These projects start with a review of any applicable regulations , LOAR program objectives and
scope of work, field procedures, safety procedures , and criteria for tagging ( e.g. process stream
applicability). Facility P&IDs/PFDs are marked up to indicate VOC Gas , Light Liquid and
Heavy Liquid streams and are backed up with detailed stream composition information. The
marked up P&IDs are used to assist in the physical tagging of components. Once components are
tagged, the fugitive emissions database is ready to be populated and monitoring routes created .
LDAR Best Practices -Sage staff have helped a number of clients identify the best ways to
approach LOAR. We typically document program strengths in our audits , and we have provided
a corporate tabulation of those strengths to several clients. Sage staff provided consulting to a
chemical facility client in Louisiana who chose to explore LOAR best practices as a beneficial
environmental project. That work involved visiting and surveying successful programs at 8
facilities and two contractor facilities. Sage is currently providing two of the three experts
involved in a comprehensive assessment of a major refinery LOAR program.
LDAR Retagging/Tag Verification -Sage staff have provided key services to clients who need
to establish or improve the basis of component identification . One such study that is currently
under way at a Texas petrochemicals site is focused on fundamental analyses of stream
composition to decide which need to be included in the LOAR program. This detailed study
involves on-site Sage staff working with modelers to translate primary stream composition data
to the diversity of lines on P&IDs. Both database and spreadsheet tools have been used to
manage the vast array of data, which involve multiple feed possibilities. Stream compositions
have been assigned to every line on the P&ID using both a worst case composition for
applicability determination and an average composition for emission inventories . In another
project, Sage staff performed extensive QNQC of flagging , tagging, and documentation of
components for a complete retagging effort for a refinery struck by Hurricane Katrina.
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LDAR Bagging Studies
Sage staff were involved in the original and follow-up studies to develop EPA emission factors
used to convert Method 21 screening results into emission rates and the emission factors
developed from the correlation equations. These landmark studies include:
~ The original refinery measurements done in the late 1970s ;
~ The original SOCMI measurements done in the early 1980s;
~ The original gas plant measurements done in the mid-l 980s ;
~ The CMA funded work done in the late 1980s; and
~ The AP I/WSP A refinery study done in the early 1990s.
Sage staff members have also performed bagging to develop site-specific correlation equations
for a number of facilities .
Smart LDAR Demonstration Studies
Sage staff have been involved in most of the large public demonstrations of infrared imaging ,
which is also known as Smart LDAR, including :
~ API funded demonstration of the Sandia Laboratory-developed fiber laser at a Texas
refinery in February 2002 ;
~ HARC/TNRCC funded demonstration of the CO2 laser at an olefins production plant in
Texas in May 2002 ;
~ HARC/TNRCC funded demonstration of the CO2 laser at an olefins production plant in
Texas in August 2002;
~ TCET/TCEQ funded five-camera demonstration at two olefins using facilitie s in Texas in
January/F ebruary 2004.
Sage staff have also worked with clients in a number of private demonstrations of Smart LDAR.
One of these was a long-term application of Smart LDAR to several project units in a Texas
refinery that included EPA NEIC involvement. Another is in a Texas refinery that negotiated the
test as part of their Consent Decree . Another private demonstration involved cross checks of
infrared imaging, Method 21 , bagging, and the Hi-Flow™ Sampler. The Hi-Flow™ Sampler
was originally de veloped as a powered dilution probe by GRI to extend the measurement
capability to very large leaks. Sage staff designed and built the second generation prototype of
the Hi-Flow™ Sampler for GRI. It has now been commercialized by JW Bacharach as a quick
alternative to bagging.
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APPENDIXC
FLIRTHERMACAM® GasFindIR CAMERA
See attached file in Adobe pdf.
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APPENDIXD
ADDITIONAL M21 MONITORING
VIA UNIT SCHEDULE COORDINATION
There are potential advantages to scheduling the infrared surveys just before or after the
scheduled Method 21 monitoring is done by the site LOAR team. This will generally work best
for smaller units where both the infrared imaging and Method 21 work can be completed within
a few days. The advantages and disadvantages of before and after scheduling are discussed
below.
Infrared Surveys Just After Site Method 21
This combination will be ideal during the early work when we are working to perfect our ability
to see all possible leaks. The Method 21 monitoring crew will have hung leaker tags for
equipment above the leak definition, so the infrared crew can spend extra time on each marked
leaker to see if it is possible to image the leak. Simultaneous Method 21 readings will be
captured by the infrared imaging crew so that we can be sure that the leak rate has not changed
since the site monitoring due to repair attempts or other factors . The additional efforts to image a
leak on each tagged leaker will include:
• Varying the imaging distance;
• Varying the background;
• Trying angles from above and below the tagged leaker;
• Using custom settings on the camera to optimize sensitivity; and
• Allowing both of the survey crew to try all the above.
When a leak can be imaged, both crew members will attempt to achieve the image again in a
normal survey mode. The factors to be evaluated during this experiment will include distance,
background, camera settings, walking vs. stopped, and panning vs. still imaging of the
component. These types of experiments will accomplish several objectives:
• Extend training on how to effectively identify leaks with infrared imaging;
• Develop a large vol ume of contemporaneous Method 21 vs. imaging data points ; and
• Concentrate a group of data points for Method 21 leaks in the area that could potentially
be imaged by infrared.
Infrared Surveys Just Before Site Method 21
Once we have completed a few units using the above technique, we can begin to perform
infrared surveys just prior to scheduled Method 21 monitoring by the site . The infrared imaging
team will then try to detect leaks with no visual cues (i.e., leaker tags) of which are likely to leak.
Once the site Method 21 monitoring has been completed, the imaging team will return to try to
image all tagged leakers that were not detected in the initial imaging survey. It is expected that
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many Method 21 leakers will not be visible with infrared imaging. Any Method 21 leaks that
can be imaged with extra effort (as described in the imaging after Method 21 section) will be
evidence of imperfections in the survey technique and/or camera settings, and these learnings
will be used to improve technique/s ettings .
This before Method 21 experiment will accomplish several objectives :
• Critical te st of survey technique ;
• Extend training on how to effectively identify leaks with infrared imaging ;
• Develop a large volume of contemporaneous Method 21 vs . imaging data points; and
• Concentrate a group of data points for Method 21 leaks in the area that could potentially
be imaged by infrared .
Application of Contemporaneous Method 21 and Infrared Surveys
There are 28 process units at the TOTAL Port Arthur refinery , and 13 of those units have around
1000 or fewer components . These smaller units would be the primary targets for
contemporaneous surveys:
Unit
Distillate Hydrotreater No . 1
Distillate Hydrotreater No . 2
Resid Solvent Extraction
Fuel Gas Treater/ Amine Unit
Sour Gas Recovery Compressors
Fuel Gas Recovery Compressors
Sour Water Stripper
SRU Complex
Jet Treater
Cogen
Transportation Fuels Blending
Marine Terminal (HON)
Truck Loading
Components
786
1,028
22
334
1,044
133
116
59
253
213
449
619
262
This list provides enough candidates for units where both surveys can be completed within a
calendar week. If scheduling of these small units does not meet the infrared survey needs , it may
also be possible to perform contemporaneous surveys on a single route out of a larger unit.
A few units will be done with the site Method 21 monitoring done first to prov ide training on
effective infrared leak detection. After that, a few units will be done with the infrared survey just
prior to scheduled Method 21 monitoring to test the effectiv eness of the infrared survey
procedures.
It may also be useful to perform some of the Part II infrared surveys contemporaneous to site
LDAR monitoring. There will be less feedback on infrared survey effectiveness in Part II , since
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most of the emphasis will be on imaging non-regulated components. It may provide some longer
term input on unit leak rates with Method 21 and infrared imaging.
Additional Data Collection
Sage plans to collect additional data about each component imaged as a leak by infrared or
discovered as a leak by Method 21 during contemporaneous surveys. The list of possible data to
be collected includes but is not limited to:
• Method 21 Results
• Date and Time
• Technician and instrument ID (TV A and Camera)
• Camera Observation Distance
o Di stance at first detection
o Farthest distance detectable
• Lighting
o Bright sun
o Cloudy bright
o Heavy overcast
o Shadow
o Other -describe
• Temperature
• Wind Speed
o Wind speed in an open area from weather station data
o Estimated wind speed at the component
• Strong wind
• Breeze
• Swirling
• Still
• Other -describe
• Precipitation
o None
o Fog
o Drizzle
o Rain
• Component Service
o Gas/Vapor
o Light Liquid
o Heavy Liquid
o Not Regulated
• Component Type
• Component Subtype
• Component Size
• Component Tag #
• Component GPS Location (if available)
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• Operating Temperature
• Operating Pressure
• Material Composition.
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APPENDIXE
ALTERNATE M ONITORING PLANS
Most Federal and State environmental rules include provisions to allow a site to propose an
alternate monitoring plan (AMP) in place of the approach specified in the rule. This appendix
discusses several potential AMPs for infrared imaging:
• LDAR for regulated components (assuming the EPA Alternate Work Practice (AWP) has
not been finalized or the TCEQ has not yet accepted the A WP);
• Cooling tower leak detection; and
• External floating roof tank seal gaps.
Each of these is discussed below.
LDAR for Regulated Co mponents
An alternate monitoring plan (AMP) for LDAR will not be necessary if the EPA Alternate Work
Practice in 40 CFR 60.18 is finalized and accepted by TCEQ. It might be necessary to develop
an AMP for infrared imaging of regulated components if TCEQ is slow to accept the EPA A WP
or if the final EPA A WP includes some unacceptable conditions. The contemporaneous infrared
and Method 21 monitoring data should provide a large volume of information about the detection
limits of infrared imaging and how to carry out an effective infrared survey. If necessary, these
data can be used to structure a white paper that could be submitted as a request for an AMP to
EPA and/or TCEQ .
Cooling Tower Leak Detection
The standard test for leaks from cooling water return lines is the El Paso method, which uses a
stripper to remove any volatile hydrocarbons from the cooling water and a portable analyzer to
measure the hydrocarbon concentration. Infrared imaging will be conducted at the same time
that the El Paso test is performed, ideally several times for several different cooling towers.
While the El Paso test is being done, the imaging team will attempt to image hydrocarbons
evaporating from the El Paso test setup as well as the cooling water return inlet to the cooling
tower and the plumes from the cooling tower fans. The key will be to see if the infrared can
image a leak that is detected by the El Paso test, so the infrared team should be called out to
survey the cooling towers every time an El Paso test finds a leak. Data will be collected showing
the relative ability to detect leaks by the El Paso test and infrared imaging. If the data looks
promising, a white paper will be prepared that could be used as part of a submittal to TCEQ
requesting an AMP for cooling towers .
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External Floating Roof Tank Seal Gaps
Infrared surveys will be conducted before , during, and after traditional seal gap measurements
are made on external floating roof tanks . Surveys conducted before traditional measurements
will show the potential for infrared to detect significant areas of leakage in a manner that is
unbiased by gap measurements. During traditional gap measurements , the technician will be
instructed to call out any gaps found above the level of significance so that the infrared operator
can attempt to imaging the leak and capture video that ties gap size to a leak image . Surveys
after traditional gap measurements will allow the infrared team to optimize their viewing angles
to try to detect any significant gaps that could not be imaged before/during traditional
measurements.
There is much informal information indicating that infrared can image leaks from floating roof
tank seals. The experiments described above could provide information to establish the relative
sensitivity of gap seal measurement vs . infrared imaging. The relative le vels of sensitivity
shown by this data could lead to varying AMP proposals :
• If gap seal measurement is more sensitive, the white paper might propose the use of
infrared surveys more frequently than current requirements for gap tests as an AMP; or
• If the infrared imaging is more sensitive, the white paper might establish the leak image
parameters that would trigger a need for seal repair as part of an AMP performed at the
current frequency for gap seal tests .
The white paper will include the camera settings and survey parameters needed to achieve results
that match those of the demonstration tests.
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Evaluating HAP Trends: A Look at Emissions, Concentrations, and
Regulation Analyses for Selected Metropolitan Statistical Areas
Regi Oommen, Jaime Hauser, Dave Dayton, and Garry Brooks
Eastern Research Group , Inc. (ERG, Inc .), 1600 Perimeter Park Dri v e, Morrisville, NC 27560
Re gi .Oommen @erg .com
ABSTRACT
EPA's annual Tr ends R eport' is tasked with characterizing the state of air quality for the nation .
Most of the reports in the past focused on criteria pollutant trends for emissions and concentrations ; few
analyses were conducted for hazardous air pollutants (HAPs) due to the limited amount of data
available. Since the passage of the Clean Air Act Amendments in 1990, much time and resources have
been directed at quantifying HAP emissions and concentrations and regulating HAP emission sources.
Historical concentration and emissions data were retrieved from EPA for select metropolitan
statistical areas (MSAs) spanning from 1990 to 2003, for the purpose of evaluating trends for specific
HAPs. Within the last 10 years , EPA has implemented several air regulations to reduce stationary and
mobile source HAP emissions , and these reductions should correspond to reductions in ambient
monitoring concentrations. Annual and seasonal trend graphs were generated to evaluate possible
correlations between the imposition of HAP regulations and reductions in HAP emissions and ambient
concentrations. Targeted HAPs for this study include : benzene, ethyl benzene, toluene , xylenes (total),
acetaldehyde, formaldehyde , and some metal compounds.
INTRODUCTION
Under earlier versions of the Clean Air Act (1960, 1963 , 1977), the primary legislative focus
from the United States Environmental Protection Agency (EPA) was on criteria pollutants (lead, NOx,
S02 , CO , PM, and VOCs). Extensive work on source characterization, control device options , and
monitoring took place under these Acts. The vast monitoring network of ambient air instruments across
the nation is used to assess the nation's air quality. These findings are reported by EPA in its annual
Tr ends Report. However, due to limited availability of data, hazardous air pollutant (HAP) trends were
not calculated.
Since the passage of the 1990 Clean Air Act Amendments (CAAA),2 EPA has spent
considerable time and resources in establishing federal regulations to reduce emissions for HAPs. The
goal of this study is to review HAP ambient monitoring, emissions, and regulatory data from the last
14 years across ten metropolitan statistical areas (MSAs) with the purpose of characterizing HAP trends
at each of these MSAs , and across the nation.
POLICY-RELEVANT QUESTIONS
In this type of study, it was important to develop conclusions based on the available data. To
guide our analyses , we asked three policy-relevant questions:
1. What are the HAP concentration trends?
2. Have HAP-specific federal regulations been effective at reducing ambient concentrations?
3. Do HAP emissions show a decline due to HAP-specific federal regulations?
To answer these three questions , we focused our study on a selected number of HAPs , specific
Metropolitan Statistical Areas (MSAs), and a study period from 1990 to 2003. Detailed information is
described below .
Pollutants of Interest
The 1990 CAAA sh aped earl y monitoring programs . The amendments emphasized collecting,
reporting , and regulating HAPs (also called air toxics). Air toxics are those pollutants known or
su spected to cause cancer or other serious health effects. Currently, 188 HAP categories (with over
700 sub s pecies) are regulated under the Clean A ir Ac t.3 The se HAPs may contribute to a wide variety
of adv erse ecosystem and health problems , including cancer and noncancer effects. Noncancer effects
include neurological effects , reproductive effects , and de velopmental effects . Emissions from multiple
sources, including major stationary, area, and mobile sources , result in population exposure to these air
toxics compounds. In some cases the public may be exposed to an individual air toxic. More typically,
howev er, people experience exposures to multiple air toxics from many emission sources . Ex posures
result not only from the direct inhalation of air toxics , but also from multi-pathway exposures such as
drinking water contaminated from airborne deposition of HAP-laden particles , deposition on skin, and
various routes to ingestion in contaminated food .
Several EPA programs have been built around subsets of the total HAPs , such as the 112(c)(6)
program,4 the l 12(k) program,5 and the core HAPs designated by EPA under the National Air Toxics
Assessment (NATA).6 For this study, we targeted the following HAPs:
HAP Type Cancer Effect Noncancer Effect
Acetaldehyde Carbonyl X X
Benzene voe X X
Cadmium Metal X X
Ethyl benzene voe X X
Formaldehyde Carbonyl X X
Lead Metal X
Mercury Metal X
Toluene voe X
Xylenes (total) voe X
Benzene , ethylbenzene , toluene , acetaldehyde, and formaldehyde do not have multiple isomers
or species, and are also considered their own pollutant group. For pollutants that have multiple isomers
or species, such as the metallic HAP compounds , averages were computed. For the individual xylene
species , the isomer concentrations were summed to compute a total xylene value. Each of the targeted
HAPs has corresponding cancer and/or noncancer toxicity factors .
MSAs of Interest
The initial list of MSAs targeted comes from ERG 's work operating EPA 's Urban Air Toxics
Monitoring Program (UATMP). For this study, we applied the MSA boundaries for year 2003 , as
designated by the Office of Management and Budget (OMB).7 An MSA is defined by the counties
associated with the MSA , as listed by the U.S . Census Bureau designations.7 For example , Camden
County, NJ (FIPS = 34007), in which CANJ (AQS site ID= 34-007-0003) is a UATMP monitor in that
county, is part of the Philadelphia-Camden-Wilmington, PA-NJ-DE-MD MSA. According to the 2003
U .S. Census Bureau , ten other counties are part of this MSA:
• New Castle County, DE (FIPS = 10003); • Chester County, PA (42029);
• Cecil County, MD (24015); • Delaware County, PA (42045);
• Burlington County, NJ (34005); • Montgomery County, PA ( 42091 );
• Gloucester County, NJ (34015); • Philadelphia County, PA ( 42101)
• Salem County, NJ (34033);
• Bucks County, PA (42017);
In 2004, several state agencies with large MSAs participated in the UATMP . Previous year-end
reports limited the geographic area to the monitor, thus limiting the number of years for constructing a
trend. For the 2004 report, the trends analyses portion increases from the participating monitor to the
monitors within the MSA, thereby potentially increasing the amount of study years available.
Of the ten MSAs ERG chose, six have monitors participating in the 2004 UATMP. Each of the
six monitors also represents one of EPA's ten regions. The remaining four MSAs represent the four
EPA regions not chosen from the UATMP report . The MSAs for this study are as follows (2004
UATMP MSAs are denoted with an*):
• Region 1: (*) Boston-Cambridge-Quincy, MA-NH MSA
• Region 2: (*) New York-Northern New Jersey-Long Island, NY-NJ-PA MSA
• Region 3: (*) Philadelphia-Camden-Wilmington, PA-NJ-DE-MD MSA
• Region 4 : (*) Tampa-St. Petersburg-Clearwater, FL MSA
• Region 5: (*) Detroit-Warren-Livonia, MI MSA
• Region 6: Dallas-Fort Worth-Arlington, TX MSA
• Region 7: (*)St.Louis, MO-IL MSA
• Region 8: Denver-Aurora, CO MSA
• Region 9 : Los Angeles -Long Beach-Santa Ana, CA MSA
• Region 10: Seattle-Tacoma-Bellevue, WA MSA
It should be noted that although the Dallas , TX MSA and Denver, CO MSA are not participating
in the 2004 UATMP, they were participants of previous UATMP years. Each MSA in this study
showed moderate to substantial increases in population and vehicle miles traveled (VMT) during the
time period considered (Table 1 ).
Time Period of Interest
Our time period for this study spanned from 1990 to 2003. The first HAP emission inventory
developed by EPA was for the 1990 base year to coincide with the passage of the 1990 CAAA. HAP
emission inventories were also developed for the 1996, 1999, and 2002 base years, thus providing
emissions data before and after several regulations from the CAAA were implemented. Specifically
over the last 10 years, EPA has implemented several air regulations to target stationary and mobile
source HAP emissions, and these reductions should correspond to reductions in ambient monitoring
concentrations and emissions.
This time period a lso captures the period where a number of federal, state, and local agency HAP
monitors and networks were placed or expanded across the nation, including the UATMP, PAMS, and
Pilot City Monitoring data sets . The time period also does not conflict with EPA's p lans for calculating
HAP trends. Beginning in 2004, EPA established a HAP monitoring network of22 sites called the
National Air Toxics Trends Subsystem (NATTS), which is to serve a simi lar function as the well-
estab lished criteria pollutant monitoring network.
METHODOLOGY
In calculating trends for this study, ERG retrieved three types of information from EPA: 1) HAP
ambient monitoring data; 2) HAP emissions data; and 3) implemented federal stationary and mobile
source rules.
Ambient Monitoring Data
The primary data sources for the HAP ambient monitoring data were from the EPA historical
archive (HA)8 and the Air Quality Subsystem (AQS).9 The HA contained nationwide HAP data from
1990-2000, while the AQS data contained state/local/tribal-submitted data for 2001-2003. Under
contract to EPA, ERG compiled, supplemented, and quality-assured the three data sources into a single
comprehensive database. The concentrations were standardized to micrograms per cubic meter (µg /m3).
Additional quality assurance /quality control (QA/QC) checks were performed on a subset of the entire
data set for approximately 30 HAPs.
To evaluate trends, ERG chose to calculate annual and seasonal MSA averages using a modified
approach to an EPA-approved procedure.10 The following steps were performed:
1. Calculate pollutant group averages. As described earlier, the metal compounds were
averaged, while the xylene species were summed together.
2. Calculate valid daily site averages.from the pollutant group averages. Most of the data
in the merged database were daily samples, and no adjustments were needed. For sub-
daily data (hourly, 3-hour, 6-hour, etc.), a minimum of 18 hours of sampling data within a
day was needed to establish a valid daily average. Thus, if a site had seventeen 1-hour
concentrations in a particular day, the average of those concentrations would not be
considered a valid daily average.
3. Calculate valid seasonal site averages.from the valid daily site averages. Each season is
assumed to have 91 days. If samples were collected l-in-6 days, then up to 15 samples
can be collected per season. Some sites sampled with less frequency, such as 1-in-12
days , which is less than 8 samples per season. For a site to have a valid seasonal average,
a minimum of seven valid daily averages is needed.
4. Calculate seasonal MSA averages from the valid seasonal site averages. The valid
seasonal averages for each site within the MSA were averaged together.
5. Calculate valid annual site averages from the valid seasonal site averages. An annual
average is the average of the valid seasonal averages. A minimum of two seasons is
needed to compute a valid annual average.
6. Calculate annual MSA averages from the valid annual site averages. The valid annual
averages for each site within the MSA were averaged together .
Table 2 summarizes the number of sites by time period and pollutant which were used in this
study. For the MSAs of interest, lead compound monitoring sites were the most prevalent for the 1990
to 1994 and the 2001 to 2003 time periods ( 110 and 84 sites, respectively). Conversely, acetaldehyde
monitoring was the lowest in the 1990 to 1994 time period (9 sites), while mercury monitoring was the
lowest for the 2001 to 2003 time period (36 sites). It should be noted that HAP ambient monitoring
sampling methods were not consistent during the entire study period, as monitoring methods have
improved over time. However, the data used for this analysis represent the best data available . No
adjustments were made to account for differences in monitoring methods .
Emissions Data
Data from the National Emissions Inventory (NE I) 11 for base years 1990 and 2002 were retrieved
from EPA for the targeted HAPs. Using an approach similar to that used for the concentration data, total
MSA emiss ions were calculated using the following steps:
1. R etriev e emiss ion s from N E!for base years 1990 and 2002 . Emissions data for 1990
were at the county -lev el , but still delineated between stationary (point sources and area
nonpoint sources) and mobile sources . Emissions data for 2002 contained stationary
source data at the facility-and county-level.
2. Calculate county-leve l emissions by HAP. Emissions for each base year were summed to
the county-level by targeted HAP. Stationary and mobile source emission types were
retained.
3 . Calculate MSA emiss ion s by HAP . Using the MSA-county designations , the MSAs of
interest were summed by HAP and emission type.
Similar to the ambient monitoring trends , emission estimation methodologies/models have
improved over the study period. However, no adjustments were made to account for these differences .
Implemented HAP Regulations
The final component for the trends analyses involves identifying implemented HAP regulations.
Federal air regulations for stationary and mobile source HAPs were researched for applicability and for
implementation dates (i.e ., when sources need to comply). Thes e dates were compiled for over sixty
regul a tions which affect our time period. All legislation corresponded to the passing of the 1990
CAAA. Specifically, Titles I, II and III of the 1990 CAAA contain legislation to reduce HAP emissions
from stationary and mobile sources :
• Under Title I, NSPS and NAAQS Programs, Solid Waste Combustion MACT Regulations and
National Volatile Organic Compound Emission Standards (NVOCES) were two of several sub-
programs to be enacted ;
• Under Title II , Mobile Sources Program, the following sub-programs were to be enacted:
1. Motor Vehicle Emission Standards (also called Tier I and Tier II);
2 . Fuel and Fuel Additives (including Prohibition of leaded gasoline);
3. Aircraft Emission Standards; and
4. Clean-Fuel Vehicles .
• Under Title III , NESHAP Program, the following sub-programs were to be enacted:
1. National Urban Air Toxics Strategy;
2 . NESHAP Standards (post-1990);
A. l 12(c)-Specific regulations for 8 HAPs;
B. l 12(d) -Specific regulations for 170+ MACT source categories ;
C. 112( f) -Residual Risk Program; and
D . 112(k)-Specific regulation for 30+ HAPs.
3. State Programs ; and
4. Accidental Release Prevention Program.
Although not considered for this study, regulations for Title IV and Title V will reduce HAPs indirectly:
• Under Title IV, Acid Rain Program, electric-generating units using coal were required to install
scrubbers to reduce criteria pollutant emi ssions , including particulate matter. Consequently,
metallic HAP concentrations should decrease accordingly . Phase I of this program was to take
place in 1995 , while Phase II was to take place in 2000.
• Under Title V , Permitting Program, state agencies is sue operating permits to facilities limiting
maximum potential emissions. These limits , typically for criteria pollutants , may indirectly
reduce HAP emi ssions .
Of the specific sub -programs listed above , only the Solid Waste Combustion MACT (Section 129), the
National VOC Emission Standards (NVOCES , Section 183 ), the Motor Vehicle Emission Standards
(Section 202), Fuel and Fuel Additives (Section 211), and over forty Section 112(d) NESHAPs have
federal regulations implemented from 1990 to 2003. Reductions due to Title V were not considered, as
they were implemented at the state -level.
To identify federal stationary source regulations for the above sub -programs, ERG used the 2002
NEI for point and area nonpoint sources for each MSA. In these inv entories , MACT codes are
identified for each facility (in the point inventory) or source category (in the area nonpoint in ventory).
Since each MSA is unique in its emission source makeup , each MSA is subject to different stationary
source regulations. Since 1990 , seventy-three of 143 MACT source categories promulgated have been
implemented .
Mobile source rules are generally for the entire country ( e.g. -National Low Emissions
Vehicles) or for specific MSAs (e.g. -Reformulated Gasoline for some ozone nonattainment areas).
NVOCES categories , such as architectural surface coating, consumer products , and autobody
refinishing , typically are found in all areas.
Table 3 is a summary of the CAAA federal regulations that were implemented during our study
period. Sixty-four HAP -specific regulations were implemented during our study period ; forty-four were
implemented between 1995 and 2001. While it 's difficult to definitively conclude that concentrations
decreased due to the implementation of certain regulations , it's useful to analyze concentrations pre-and
post-implementation to conclude an apparent effect on emissions .
RESULTS
The combination of the ambient monitoring data, emissions data, and implementation dates of
stationary and mobile source rules were the basis for our trends analysis . The following sections
describe the concentration and emissions trends for each MSA. Tables 4a-i provide an emissions and
concentration trends summary by HAP and MSA . Due to availability of ambient monitoring data, we
chose to average 1990-1994 concentrations and 2002 -2003 concentrations . To evaluate a trend, we
compared the average concentrations from two time periods . For each MSA and HAP , there were
57 combinations which had concentration values during both of these time periods; of those, over 85 %
of the HAPs measured across the ten MSAs presented a decrease in their HAP concentrations .
These sub-time periods overlap with the NEI baseyear (1990-1993) and latest year (2002)
emissions inventory . When comparing emission estimates from the 1990 NEI and the most recent 2002
NEI, HAP emissions for each MSA decreased substantially; total emissions across the MSAs decreased
from 580,000 tpy to 270,000 tpy (53% reduction).
An interesting observation in this study was the relationship between reducing emissions and the
apparent effect on concentrations. More than half of time period comparisons in emissions and average
concentration (30 of 57) realized percentage reductions within 20% of each other, with one as close as
1 %; the Los Angeles MSA total xylene emissions decreased by 73%, while average concentration
decreased by 74% (Table 4i).
Regulation impact analyses figures were constructed for each MSA and pollution group, and are
posted at Eastern Research Group's FTP site 12 due to space limitations for this paper. However, for this
paper, we have included two figures per MSA. Implemented regulations are coded in the figures using
the graph key from Table 3.
Boston MSA
• The Boston MSA experienced a 7% increase in population and a 74% increase in vehicle miles
traveled (VMT) from 1990 to 2003. This MSA participated in the winter-oxygenated program
from 1992 to 1996 and the reformulated gasoline program during the study period.
• Although there were increases in population and VMT during the study period, the emissions for
all the pollutants of interest decreased from 30% (acetaldehyde) to 84% (mercury). The VOC
and metal HAPs decreased in their average concentrations, ranging from 47% (ethylbenzene) to
94% (total xylenes). Acetaldehyde and formaldehyde concentrations, in contrast, increased
during our study period ( +640% and + 300%, respectively).
• The Boston MSA phased out of the winter-oxygenated fuel program in 1996, but still
participates in the reformulated gasoline (RFG) program. According to Figures 2 and 3,
acetaldehyde and formaldehyde concentrations appeared to increase after the implementation of
RFG Phase II and the POTW MACT. Since emissions for these HAPs have decreased
substantially, this may suggest that they are forming as secondary pollutants . Research has
shown increases in carbonyl concentrations due to implementations of the RFG Program (Phase I
and Phase Il).13
New York City MSA
• The New York MSA experienced an 11 % increase in population and a 29% increase in VMT
from 1990 to 2003. This MSA participated in the winter-oxygenated program and the
reformulated gasoline program during the study period.
• Although there were increases in population and VMT during the study period , the emissions for
all the pollutants of interest decreased from 29% (total xylenes) to 84% (mercury). Similarly, all
the pollutants of interest decreased in their average concentrations, ranging from 24% ( cadmium)
to 95% (mercury).
• Benzene concentrations in the New York MSA decreased , as shown in Figure 4, after
implementation of mobile source rules (winter-oxygenated fuel and reformulated gasoline). The
federal rules targeting stationary sources (Degreasing, Gasoline Distribution Stage I, etc .) did not
appear to reduce benzene concentrations .
• Mercury concentrations appeared to decrease after implementation of the Petroleum Refineries
MACT, Reformulated Gasoline Phase II program, and the Large Municipal Waste Combustors
MACT (Figure 5).
Philadelphia MSA
• The Philadelphia MSA experienced a 6% increase in population and a 57% increase in VMT
from 1990 to 2003. This MSA participated in the winter-oxygenated program and the
reformulated gasoline program during the study period.
• Although there were increases in population and VMT during the study period, the emissions for
all the pollutants of interest, except for cadmium, decreased from 49 % (lead) to 71 % (mercury).
Cadmium emissions increased 110 %. All the pollutants of interest, except cadmium, decreased
in their average concentrations, ranging from 65 % (benzene) to 99 % (lead). Average cadmium
concentrations increased from 0.45 ng/m3 to 4 .6 ng/m3 .
• Closer examination of the emissions data indicates a possible error in the 2002 area nonpoint
emission estimates for three combustion categories in the Philadelphia MSA : industrial boilers
using residual oil , institutional/commercial heating using residual oil, and industrial boilers using
bituminous and lignite coal. The total cadmium emissions for these three categories in the
Philadelphia MSA increased from 0.038 tons per year in 1990 to 5.7 tons per year in 2002 , which
matches the large increase in cadmium emissions .
• Cadmium compound concentrations appeared to increase throughout the study period in the
Philadelphia MSA (Figure 6); however, limited or no data are available from 1998-2000. There
was one site (AQS ID= 42-045-0002) which measured cadmium in both time periods . Average
concentrations increased from 0.45 ng/m 3 in the early time period to 4.3 ng/m 3 in the later time
period, which matches the trend in Table 4c.
• As shown in Figure 7, lead compound concentrations appeared to decrease substantially after
implementation of the Secondary Lead Smelter MACT and the Gasoline Distribution Stage I
MACT.
Tampa Bay MSA
• The Tampa Bay MSA experienced a 22% increase in population and a 73% increase in VMT
from 1990 to 2003 . This MSA does not participate in either the winter-ox ygenated program or
the reformulated gasoline program.
• Although there were increases in population and VMT during the study period, the emissions for
all the pollutants of interest decreased , ranging from 22 % (benzene) to 96 % (cadmium). Lead
was the only HAP to have a 1990-1994 average calculated , and that concentration decreased by
61 %. Limited or no data were available for the other HAPs during thel990-1994 time period.
• According to Figure 8, lead compound concentrations appeared to decrease overall during the
study period, most notably after the Secondary Lead Smelting MACT.
• Although toluene concentrations have decreased during the study period (Figure 9), there is
limited toluene data in the Tampa MSA for the last five years , thereby making it difficult to
establish a trend.
Detroit MSA
• The Detroit MSA experienced a 6% increase in population and a 29 % increase in VMT from
1990 to 2003 . This MSA does not participate in either the winter-oxygenated program or the
reformulated gasoline program.
• Although there were increases in population and VMT during the study period, the emissions for
all the pollutants of interest, except cadmium and lead , decreased ranging from 32 % (benzene) to
79 % (mercury). Cadmium and lead emissions increased by 36 % and 67 %, respectively .
Concentrations for the VOC HAPs and for lead decreased during the study period , ranging from
9% (ethylbenzene) to 39 % (lead). Limited or no data were available for the acetaldehyde,
cadmium, formaldehyde, or mercury during the 1990-1994 time period.
• Closer examination of the cadmium emissions data shows a large cadmium emission source,
Perma-Fix of Michigan, reporting emissions at 1.50 tons in 2002 . This facility is not accounted
for in the 1990 NEI , thereby explaining the increase in MSA emissions. It is assumed that this
facility was not operational in 1990 or the emissions were below reporting thresholds. If those
emissions are removed , then the emissions decrease by 53 %.
• Closer examination of the 2002 lead emissions shows that over 17 tons are emitted from two oil-
fired utility boilers , Detroit Edison Greenwood Energy Center and St. Clair/Belle River Power
Plant. In 1990, the entire emissions from oil-fired utility boilers for the Detroit MSA is
0.21 tons , suggesting that the 1990 estimates are too low.
• Lead concentrations in Detroit appeared to decrease steadily during the study period (Figure 10).
The biggest effect appears to be related to the implementation of the Large Municipal Waste
Combustors MACT .
• Although total xylene concentrations had little variance throughout the 1990s (Figure 11 ), it is
unclear how stationary source rules affected xylene concentrations due to the limited data
availability of xylene measurements from 1997-2000, when several regulations were
implemented.
Dallas MSA
• The Dallas MSA experienced a 40% increase in population and a 36% increase in VMT from
1990 to 2003. This MSA participated in the reformulated gasoline program during the study
period .
• Although there were increases in population and VMT during the study period, the emissions for
all the pollutants of interest decreased from 36% (total xylenes) to 83% (cadmium). All the
pollutants of interest decreased in their average concentrations , ranging from 36 % (benzene and
lead) to nearly 100 % (mercury). Limited or no data were available for acetaldehyde , cadmium,
or formaldehyde during the 1990-1994 time period .
• Benzene concentrations in Dallas show a downward trend (Figure 12), primarily in response to
implementation of Tier 1 Mobile Standards .
• Mercury compound concentrations appeared to have decreased substantially with the
implementation of the Reformulated Gasoline Phase 1 Program (Figure 13). However,
according to the NEI , mercury emissions from Hazardous Waste Combustors decreased by 97 %
from 1996 to 2002 for this MSA , most likely a s a result of impending regulations.
St. Louis MSA
• The St. Louis MSA experienced a 6% increase in population and a 38 % increase in VMT from
1990 to 2003 . This MSA participated in the reformulated gasoline program during the study
period.
• Although there were increases in population and VMT during the study period , the emissions for
all the pollutants of interest decreased from 46 % (acetaldehyde) to 89 % (lead). All the pollutants
of interest , except acetaldehyde , ethylbenzene , and formaldehyde decreased in their average
concentrations , ranging from 21 % (toluene) to ne arly 89 % (total xylenes). Average
acetaldehyde, ethylbenzene, and formaldehyde concentrations increased 79 %, 9%, and 222 %,
respectively .
• Overall , cadmium compound concentrations in the St. Louis MSA appeared to have decreased
during the study period (Figure 14). The implementation of the Reformulated Gasoline Phase 2
Program and the Primary Lead Smelting MACT coincide with these reductions. However, no
implemented regulations explain the increases and decreases in the 1996 , 1997 , and 1999
concentrations .
• Total xylene concentrations in the St. Louis MSA declined dramatically in apparent response to
several implemented stationary and mobile source regulations targeting VOCs (Figure 15).
However, the lack of xylene data measurements between 1995 and 2000 limit the certainty of
these conclusions .
Denver MSA
• The Denver MSA experienced a 39% increase in population and a 75 % increase in VMT from
1990 to 2003 . This MSA participated in the winter-oxygenated program, but not the
reformulated gasoline program during the study period.
• Although there were increases in population and VMT during the study period, the emissions for
all the pollutants of interest decreased , ranging from 11 % (lead) to 97 % (mercury). Cadmium
and lead were the only HAPs to have 1990 -1994 averages calculated , and those concentrations
decreased by 90% and 54%, respectively. Limited or no data were available for the other HAPs
during the 1990 to 1994 time period.
• As shown in Figure 16 , over the last four years , acetaldehyde concentrations appeared to
decrease after implementation of mobile source rules (winter-oxygenated fuel program and the
National Low Emissions Vehicle Program Phase II).
• For the cadmium trend (Figure 17), no implemented stationary source regulations were identified
in the Denver MSA which affected cadmium concentrations . To understand this decline, we
reviewed the NEI and Toxic Release Inventory 14 from 1990 -1994 for cadmium emissions. One
facility , Asarco , Inc. Globe Plant, which is a cadmium refining and cadmium oxide production
plant reported emissions in 1990 as 0 .20 tpy. By 1994 , the emissions decreased to 0 .078 tpy, a
61 % decrease in emissions . Emissions at this plant through 2002 remain constant. It 's likely
that the decrease in cadmium emissions from this plant contributed to the decrease in ambient
cadmium concentrations.
Los Angeles MSA
• The Los Angeles MSA experienced a 14% increase in population and a 16 % increase in VMT
from 1990 to 2003. This MSA also participated in the winter-oxygenated program and the
reformulated gasoline program during the study period.
• Although there were increases in population and VMT during the study period, the emissions for
all the pollutants of interest decreased from 40% (acetaldehyde) to 81 % (mercury). Similarly, all
the pollutants of interest decreased in their average concentrations , except for cadmium and
formaldehyde , ranging from 24% (acetaldehyde) to 85 % (lead). Average cadmium
concentrations increased from 0.78 ng/m3 to 3.79 ng /m3 , while formaldehyde concentrations
increased by 65 %.
• There was one site (AQS ID= 06-037-1103) which measured cadmium in both time periods.
Average concentrations increased from 0.95 ng/m 3 in the early time period to 3.8 ng/m3 in the
later time period, which is similar to the MSA concentration increase presented in Table 4c.
Cadmium emissions, however, decreased by 51 %. This observation suggests that most likely the
emission inventories are incorrect, and need to be further investigated.
• Ethylbenzene concentrations in the Los Angeles MSA declined steadily in apparent response to
several implemented stationary and mobile source regulations targeting VOCs (Figure 18).
• Formaldehyde concentrations have steadily increased during the study period (Figure 19). This
is most likely due to the implementations of the RFG Program (Phase I and Phase II), which
creates formaldehyde secondarily . This trend was observed in the Boston MSA.
Seattle MSA
• The Seattle MSA experienced a 23% increase in population and a 27 % increase in VMT from
1990 to 2003. This MSA participated in the winter-oxygenated program from 1992-1996, but
not the reformulated gasoline program.
• Although there were increases in population and VMT during the study period, the emissions for
all the pollutants of interest decreased ranging from 25% ( ethylbenzene and total xylenes) to
91 % ( cadmium and mercury). Lead was the only HAP to have a 1990-1994 average calculated,
and that concentration decreased by 96%. Limited or no data were available for the other HAPs
during the 1990 to 1994 time period.
• Over the last three years , formaldehyde concentrations appeared to have increased, noticeably
after the implementation of the Publicly Owned Treatment Works MACT (Figure 20). However,
formaldehyde data prior to 2001 are limited or unavailable, thus making it difficult to
characterize a trend.
• During the study period, lead concentrations appeared to have decreased (Figure 21). After
implementation of the Petroleum Refineries and Aerospace Manufacturing MACTs ,
concentrations decreased substantially. Interestingly, lead concentrations increased after the
prohibition of leaded gasoline .
CONCLUSIONS
Nine HAPs were analyzed for MSAs across the United States. Each MSA was chosen from one
of EPA's ten regions. ERG used a database consolidated from EPA's Historical Archive and from the
Air Quality Subsystem to calculate annual average concentrations. Emissions for each HAP were
retrieved from EPA's National Emissions Inventory, 1990 to 2002. Information on federal regulations
were researched from the 1990 Clean Air Act Amendments (CAAA). Three policy-relevant questions
were used to guide our study, and we answer these questions below:
• What are the hazardous air pollutant (HAP) concentration trends? When comparing
concentrations between 1990-1994 and 2002-2003 , over 85% of the MSA-HAP combinations
measured across the ten MSAs realized a decrease in their HAP concentrations , while less than
15 % realized an increase . This observation would suggest that most HAPs had a decreasing
trend during the study period. For example, lead compound concentrations decreased in all ten
MSAs (range 36% to 99%), while benzene decreased in seven (range 19% to 79%). However,
acetaldehyde , cadmium compounds , ethylbenzene , and formaldehyde each had at least one MSA
that computed an increasing trend. Additionally, more than half of the percentage reduction
comparisons for concentrations and emissions (30 of 57) were within 20% of each other, with
one as close as 1 % ( e.g., Los Angeles total xylene emissions: 73% decrease in emissions, 74%
decrease in average concentration).
• Have HAP-specific federal regulations been effective at reducing ambient concentrations?
Sixty-four HAP-specific regulations were implemented between 1992 and 2003. During that
time period, most HAP concentrations decreased, suggesting a correlation between the two. The
most effective regulations on pollutant types, based on visual inspection of the regulation impact
analysis figures, were :
1. VOCs: Reformulated Gasoline Phase I, VOC rules , Printing/Publishing MACT, Tier 1
Mobile Source Standards, Reformulated Gasoline Phase II
2. Carbonyls : Reformulated Gasoline Phase I , National Low Emissions Vehicle Program Phase
II, Pharmaceuticals Production
3. Metals : Prohibition of Leaded Gasoline, Aerospace Manufacturing MACT, Petroleum
Refineries MACT , Reformulated Gasoline Phase II, Large Municipal Waste Combustors
MACT, Secondary Lead Smelter MACT, Stage I Gasoline Distribution MACT, Primary
Lead Smelter MACT
• Do HAP emissions show a decline due to HAP-specific federal regulations? When comparing
emission estimates from the 1990 NEI and the most recent 2002 NEI, HAP emissions for each
MSA decreased substantially. Total HAP emissions across the ten MSAs decreased from
580 ,000 tpy to 270,000 tpy (53% reduction). Emissions in the Los Angeles MSA decreased the
most among the MSAs (69% reduction, 86 ,000 tpy). For the HAPs , mercury emissions realized
the highest percent reduction (80%), while toluene emissions realized the highest mass reduction
(140 ,000 tpy). Between 1991 and 2001 , over 40 HAP-specific regulations were implemented,
suggesting that HAP emissions declined due to these regulations.
Using the above observations, the implementation of HAP-specific federal regulations coincides
favorably with reductions in emissions and ambient concentrations for benzene, ethylbenzene, lead
compounds , mercury compounds, toluene , and xylenes.
REFERENCES
l. U.S. EPA. Latest Finding on Air Quality: 2002 Status and Trends. OAQPS. EPA 454/K-03-001.
August 2003. Internet address: http://www.epa.gov/airtrends /2002 airtrends final.pdf
2. U.S. EPA. Clean Air Act Amendments. OAQPS. Internet address:
http://www.epa.gov/ air/ oaq caa.html/
3. U.S . EPA. The Original List of Hazardous Air Pollutants. Internet address:
http://www.epa.gov/ttn/atw/origl 89.html
4. U.S. EPA. Notice of Source Category Listings for Specific Pollutants: Section 112(c)(6). Internet
address: http://www.epa.gov/ttn/atw/112c6/112c6fac.html
5. U.S. EPA. Air Toxics Strategy: Overview. Internet address:
http://www.epa.gov/ttn/atw /urban/urbanpg.html
6. U.S. EPA. The National-Scale Air Toxics Assessment. Internet address:
http://www.epa.gov/ttn/atw /nata/
7. U.S. Census Bureau. Metropolitan and Micropolitan Statistical Areas, 2003. Internet address:
http://www. census. gov /population/www/ estimates/metroarea.htm I
8. U.S. EPA. Historical Archive of Ambient Monitoring Data. Data retrieved from Mr. Jawad Touma,
U.S. EPA.
9. U.S. EPA. About the AQS Subsystem. Internet address: http://www.epa.gov/air/dat a/a gsdb .htm l
10. Sonoma Technologies, Inc. (STI). Database Overview: Cleaning and Averaging. Presentation by
Dr. Michael McCarthy, STI. Presented to the Workshop on Air Toxics Data Analysis. Rosemont,
IL. June 2-3, 2004. Internet address:
http://www.ladco.org/toxics/AT%20presentations%20pdf/Database preparation.pdf
11. U.S. EPA. National Emission Inventories for the U.S. Internet address:
http://wv.,rw .epa.gov/ttn/chief/net/index.html
12 . Eastern Research Group, Inc. FTP site: ftp://ftp.erg.com/outgoing/Trends/
13. Northeast States for Coordinated Air Use Management (NESCAUM). RFG/MTBE: Findings and
Recommendations. NESCAUM. August 1999. Internet address:
http://www.nescaum.org/pdf/MTBE PH2/Ph2surnm .pdf
14. U.S. EPA. Toxic Release Inventory (TRI) Program. Internet address: http://www.epa.gov/tri/
KEYWORDS
Hazardous Air Pollutants (HAPs)
HAP Concentration Trends
Regulation Analysis
HAP Emission Trends
Metropolitan Statistical Areas
Ambient Air Monitoring
Ambient Concentration Trends
Table 1. Population and Vehicle Miles Traveled (VMT) Profiles for Each MSA
MSA MSA %Change 1990 MSA 2003 MSA %Change Winter-Oxygenated
Population Population inMSA VMT VMT inMSA Time Period MSA Reformulated
MSA in 1990 in 2003 Population (thousands) (thousands) VMT Implemented Gasoline Desi2nation
Boston MSA 4 ,133 ,895 4,439,971 +7% 18 ,730 ,000 32 ,600,000 +74% 1992 -1996 Opt-In
New York MSA 16 ,863 ,671 18 ,640 ,775 + 11 % 82 ,100 ,000 106,000 ,000 +29 % 1992-2000 Required
Philadelphia MSA 5 ,435 ,550 5 ,772 ,947 +6% 24 ,000 ,000 37 ,600 ,000 +57 % 1992-1996 Required
Tampa Bay MSA 2 ,067 ,959 2,531 ,908 +22 % 12 ,300,000 21 ,300 ,000 +73 % NA NA
DetroitMSA 4,248 ,699 4 ,483 ,853 +6% 28 ,600 ,000 36 ,800 ,000 +29% NA NA
Dallas MSA 3,989 ,294 5 ,589,670 +40 % 29 ,300,000 39 ,800 ,000 +36% NA Opt-In
St. Loui s MSA 2 ,599,893 2 ,759 ,440 +6% 16 ,500 ,000 22 ,800 ,000 +38 % NA Opt-In
Denver MSA 1,650,489 2 ,301 ,116 +40 % 9,910,000 17 ,400 ,000 +75 % 1992 -2003 NA
Los Angele s MSA 11 ,273 ,720 12,829 ,272 + 14% 91 ,500,000 106 ,000 ,000 + 16% 1992-2003 Required
Seattle MSA 2,559,136 3,141,777 +23 % 19 ,200,000 24 ,400 ,000 +27 % 1992-1996 NA
Table 2. Number of Ambient Monitors Used For Trends Analysis
Time MSA Period
Boston MSA 1990-1994
2002 -2003
NewYorkMSA 1990 -1994
2002-2003
Philadelphia 1990-1994
MSA 2002 -2003
Tampa Bay 1990-1994
MSA 2002-2003
DetroitMSA 1990-1994
2002-2003
Dallas MSA 1990-1994
2002-2003
St. Louis MSA 1990 -1 994
2002 -2003
D enver MSA 1990-1994
2002-2003
Los Angeles 19 90-1994
MSA 2002 -200 3
Seattl e MSA 1990-1994
2002-2003
TOTAL 1990-1994
2002-2003
ACET = acetaldehyde
B ENZ = benzene
CAD = cadmium compounds
ACET BENZ CA D
A' B' A' B' A'
I I 2
I 0 9
2 2 2
0 0 5
0 0 7
0 0 3
1 0 2
0 0 l
4 4 6
0 0 2
9 7 39
3 I 0
4 2
5 0 4 -14 8
2 2 I -5 6
0 0 0 -
0 l
2 2 0 -7 7
2 0 0 -8 4
2 0 7 -
4 4
0 0 4 -
3 3
8 6 3
7 1
0 0 0 -2 5
24 11 19
54 41
ETHYL = e thylbenzene
FORM = forma ldehyde
LEAD = lead compounds
A= N umb er of ambient monitors used for analysis
3 B = Number of common monitors be tween time periods
B'
0
1
l
0
0
0
0
0
l
0
3
POLLUTANT 1
ETHYL FORM LEAD
A' B' A' B' A' B'
l I l I 2 I 4 2 3
5 0 I 0 14 2 14 9 10
2 2 2 2 18 4 5 2 7
0 0 0 0 3 2 0 5 4
2 2 0 0 3 2 7 7 7
2 0 0 0 24 6 7 3 11
1 0 1 0 23 8 4 2 12
0 0 0 0 7 3 3 l 5
4 3 6 5 12 6 6 6 8
0 0 0 0 4 I 0 2 8
17 8 11 8 110 35 50 39
MERC = mercury compounds
TOL = toluene
XYL = total xylene
75
MERC TOL XYL
A' B' A' B' A' BJ
0 0 3 l 2 I -2 4 4
4 0 5 0 5 0 >---
7 14 14
0 0 2 2 2 2 -6 5 5
0 0 0 0 0 0 >---
1 0 0
0 0 2 2 2 2 -2 7 7
l 0 2 0 2 0 >---
4 8 7
8 0 2 0 2 0 -4 4 4
0 0 0 0 0 0 >---
l 3 3
3 l 8 6 6 4 -1 7 7
0 0 0 0 0 0 >---
6 0 0
16 1 24 11 21 9 34 52 51
Table 3. Implemented Federal Regulations from 1990 Clean Air Act Amendments , 1992-2003
Graph Implementation Targeted
Key Regulation Date HAPs 1
a Winter-Oxygenated, Season I 11/1/1992 V,C,M
b Winter-Oxygenated, Season 2 11/1/1993 V,C,M
C Winter-Oxygenated, Season 3 11/1/1994 V,C,M
d Reformulated Gasoline (RFG) -Stage I 1/1 /1995 V,C,M
e Winter-Oxygenated, Season 4 11/1/1995 V,C,M
f Coke Ovens 12/31/1995 V
g Prohibition of Leaded Gasoline for Motor Vehicles 1/1/1996 M
h Chromium Electroplating 1/25 /1996 V
i Industrial Cooling Towers 3/8/1996 NA
j Final phase-in of Ti er I Standards 8/1/1996 V,C
k Dry Cleaners 9/23 /1996 NA
I Winter-Oxygenated, Season 5 11 /1/1996 V,C,M
m Magnetic Tape (surface coating) 12/15 /1996 NA
n Shipbuilding and Ship Repair (surface coating) 12/16/1996 V
0 Polymers and Resins Manufacturing I 7/31/1997 NA
p Polymers and Resins Manufacturing IV 7/31/1997 V,M
q Winter-Oxygenated, Season 6 11/1/1997 V,C,M
r Wood Furniture (surface coating) 11/21 /1997 V,C
s Degreasing Organic Cleaners 12/2/1997 V
t Gasoline Distribution Stage I 12/15/1997 V,C
u Secondary Lead Smelting 12/23/1997 M
V National Low Emissions Vehicle Program -Stage I 8/1/1998 V,C
w Petroleum Refineries 8/18/1998 V,C,M
X Aerospace Manufacturing (surface coating) 9/1/1998 V,C,M
y Winter-Oxygenated, Season 7 11 /1/1998 V,C,M
z National VOC Emission Standard for Consumer Products 12/10/1998 V,C
A National VOC Emission Standard for Autobody 1/1/1999 V,C
Refini shing
B Hazardous Organic NESHAP 5/12/1999 V ,C
C Printing and Publishing (surface coating) 5/30/1999 V,C,M
D California Low Emissions Vehicle Program -Stage I 8/1/1999 C
E National VOC Rule for Architectural Surface Coating 9/1 3/1999 V ,C
F Marine Vessel Loading 9/19/1999 V
G Primary Aluminum Manufacturing 10/7/1999 V
H Winter-Oxygenated, Season 8 11/1/1999 V,C,M
I Reformulated Gasoline (RFG) -Stage II 1/1 /2000 V,C,M
J Off-Site Waste Recovery Operations 2/1/2000 NA
K National Low Emissions Vehicle Program -Stage II 8/1/2000 V,C
L Winter-Oxygenated, Season 9 11/1/2000 V,C,M
M Municipal Waste Combustors -Large Units 12/19/2000 C,M
N Pulp and Paper I 4 /15/2001 V,M
0 Pulp and Paper II 4/16/2001 V,M
p Primary Lead Smelting 6/4/2001 M
Pl Steel Pickling -HCI Process 6/22/2001 NA
Q Pharmaceuticals Production 9/21/200 I V,C,M
R Flexible Polyurethane Foam Production 10/8/2001 V
s Winter-Oxygenated, Season 10 11/1/2001 V,C,M
T Ferroalloys Production 11 /21/2001 NA
u Mineral Wool Production 6/1/2002 NA
V Polye ther Polyols Production 6/1/2002 NA
w Phosphate Fertilizer Production 6/10/2002 NA
X Pho sphoric Acid Manufacturing 6/10/2002 M
y Portland Cement Manufacturing 6/14/2002 V,C,M
z Wool Fiberg la ss Manufacturing 6/14/2002 V,C
Table 3. Implemented Federal Regulations from 1990 Clean Air Act Amendments, 1992-2003
(Continued)
Graph Implementation Targeted
Key Regulation Date HAPs 1
0 Natural Gas Transmission and Storage 6/17/2002 V,C
I Oil and Natural Gas Production 6/17/2002 V,C,M
2 Generic MACT 6/29 /2002 M
3 Ho sp ital , Medical, Infectious Waste Incinerators 9/15/2002 M
4 Publicly Owned Treatment Works 10/26/2002 V,C,M
5 Winter-Oxygenated, Season 11 11/1/2002 V,C,M
6 Polymers and Resins Production III 1/20/2003 V,C,M
7 Secondary Aluminum Production 3/24/2003 V,C,M
8 Hazardous Waste Combustion 9/30/2003 M
9 Winter-Oxygenated, Season 12 11 /1/2 003 V,C,M
10 Pe stici de Active Ingredients Manufacture' 12/23 /2003 V
1 = NA: Not Applicable; V = VOC HAPs; C = carbonyl HAPs ; M = metal HAPs
2 = The implementation date for thi s MACT, although occurring in 2003, would be considered part of the winter 2004 time
perio d, and was not be considered for this study.
Table 4a. Acetaldehyde Emission (tpy) and Concentration (µg/m 3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Boston MSA 1,100 790 -30 % 2 .8 ± 0 .5 20.4 ± 5.3 +630 %
New York MSA 3,100 1,300 -57 % 4 .2 ± 1.3 1.9 ± 0 .1 -55 %
Philadelphia MSA 1,200 620 -50% 3.4 ± 0 .5 1.0 ± 0 .2 -72 %
Tampa Bay MSA 540 360 -34% NA 2.1 ±0.1 NA
Detroit MSA 1,200 630 -47 % NA 1.8 ± 0 .1 NA
Dallas MSA 1,200 570 -54% NA 1.8 ± 0 .1 NA
St. Louis MSA 820 450 -46% 2 .6 ± 1.2 4 .6 ± 0.4 +79 %
DenverMSA 660 440 -33 % NA 2.5 ±0.2 NA
Los Angele s MSA 2,400 1,400 -40% 4 .7 ± 0 .3 3 .6 ± 0.3 -25 %
Seattle MSA 1,100 600 -44 % NA 1.7 ±0 .1 NA
Table 4b. Benzene Emission (tpy) and Concentration (µg/m 3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Bo ston MSA 6,300 2,200 -64% 3 .9 ±0 .6 0 .8 ±0 .1 -80%
NewYorkMSA 17 ,000 7,500 -55 % 3.2 ±0.2 1.4 ± 0.1 -59 %
Philadelphia MSA 6,000 2,600 -57% 3 .6 ± 0.3 1.3 ± 0.1 -65 %
Tampa Bay MSA 3 ,100 2,400 -22 % NA NA NA
Detroit MSA 6 ,500 4 ,400 -32 % 4.2 ± 0 .5 3.4 ± 1.2 -19 %
Dallas MSA 7,900 2,800 -64% 1.2 ± 0 .1 0 .8±0.1 -36 %
St. Louis MSA 4 ,400 2,300 -47 % 5 .2 ± 2 .2 1.4 ± 0.1 -72 %
DenverMSA 2 ,800 1,900 -32 % NA 2 .8 ±0.2 NA
Los Angeles MSA 20 ,000 4 ,200 -79 % 9.0 ± 0.5 2 .3 ±0.1 -74 %
Seattle MSA 5,800 4,300 -26 % NA 1.4 ± 0 .2 NA
Table 4c . Cadmium Compound Emission (tpy) and Concentration (ng/m3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Boston MSA 1.0 0.4 -62 % NA 2 .1 ±0.2 NA
New York MSA 3 .7 0 .9 -75 % 5.1 ± 0.4 3 .9 ± 0 .3 -24%
Philadelphia MSA 2 .9 6 .3 +110% 0 .5 ± 0 .1 4 .6 ± 0 .5 +910 %
Tampa Bay MSA 9 .0 0 .3 -97 % NA 5 .0 ± 0.8 NA
Detroit MSA 1.7 2.3 36% NA 1.3 ± 0.2 NA
Dallas MSA 4.7 0 .8 -83% NA 3.0 ± 0 .3 NA
St. Louis MSA 8.7 2 .7 -69% 16 .3 ± 3 .2 3.4 ± 0.5 -79 %
DenverMSA 0.4 0 .2 -54% 31.7±8 .4 3 .2 ± 0 .6 -90 %
Los Angeles MSA 2.9 1.4 -51 % 0.8 ± 0 .1 3.8 ± 1.1 +390 %
Seattle MSA 1.0 0 .1 -91 % NA 2 .0 ± 0.3 NA
Table 4d. Ethylbenzene Emission (tpy) and Concentration (µg/m 3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Boston MSA 2,600 1,100 -58% 1.0 ± 0.1 0 .5 ± 0 .1 -47%
New York MSA 8,400 4 ,200 -50% 2.1 ± 0 .1 0.7 ± 0 .1 -65%
Philadelphia MSA 3,400 1,300 -60% 1.6 ± 0 .2 0 .5 ± 0.1 -66 %
Tampa Bay MSA 1,600 1,100 -27% NA NA NA
Detroit MSA 3,300 1,800 -44% 1.4 ± 0 .2 1.3 ± 0.3 -9 %
Dallas MSA 3,500 1,500 -57 % 0.7 ± 0.1 0 .3 ± 0 .1 -64 %
St. Louis MSA 2 ,100 1,100 -47 % 0 .8 ± 0.4 0 .8 ± 0.1 +9 %
Denver MSA 1,300 780 -38 % NA 1.6 ± 0 .2 NA
Los Angeles MSA 7,600 1,900 -75% 3.9 ± 0.3 1.5 ± 0 .1 -61 %
Seattle MSA 2,300 1,700 -25 % NA NA NA
Table 4e. Formaldehyde Emission (tpy) and Concentration (µg/m 3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Boston MSA 3,700 1,800 -51 % 3 .9±0.8 15 .0 ± 4 .8 +300 %
NewYorkMSA 10 ,000 4,000 -62 % 6 .5 ± 2.4 3 .2 ± 0.3 -52 %
Philadelphia MSA 4 ,300 2,100 -51 % 4 .2 ± 0 .3 1.7 ± 0 .5 -61 %
Tampa Bay MSA 1,700 1,100 -38 % NA 3.4 ± 0.4 NA
Detroit MSA 4 ,100 1,700 -59% NA 4 .0± 0 .7 NA
Dallas MSA 4 ,300 1,800 -59% NA 3.8 ± 0.3 NA
St. Louis MSA 2,700 1,300 -53 % 4.1 ± 1.7 13.0 ± 1.3 +220%
Denver MSA 2,200 1,100 -51 % NA 2 .8 ± 0 .2 NA
Los Angeles MSA 8,000 4,700 -41 % 3.3 ±0.2 5.4 ± 0 .3 +65 %
Seattle MSA 3,200 1,900 -41 % NA 2 .6± 0 .6 NA
Table 4f. Lead Compound Emission (tpy) and Concentration (ng/m3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Bo ston MSA 15.0 7.0 -54 % 47.6 ± 2.7 9.0±0.7 -81 %
NewYorkMSA 86 .0 22.3 -74 % 109.6± 16 .6 10 .9 ± 1.5 -90 %
Philadelphia MSA 69 .8 35 .6 -49 % 848 .0± 113 .6 11.7 ± 0 .9 -99 %
Tampa Bay MSA 21.8 7 .2 -67 % 612.8 ± 83.9 237 .0 ± 43 .0 -61 %
Detroit MSA 19.0 31.7 +67% 24 .9 ± 1.8 15 .2 ± 0 .9 -39 %
Dallas MSA 38.1 22 .9 -40 % 124 .2 ± 8.7 79 .3 ± 8.5 -36 %
St. Louis MSA 223.1 23 .7 -89 % 785.1 ± 77.7 293.8 ± 60 .1 -63 %
DenverMSA 7.7 6.9 -11 % 71.3±4.1 32 .9 ± 5 .0 -54 %
Los Angeles MSA 63.5 28.4 -55 % 125.4± 14.2 19 .0 ± 1.9 -85 %
Seattle MSA 16 .3 3.7 -78 % 116.5 ±19 .7 4.4 ± 0 .3 -96 %
Table 4g. Mercury Compound Emission (tpy) and Concentration (ng/m3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Boston MSA 3.4 0 .5 -84 % NA 0 .9±0.1 NA
NewYorkMSA 7 .6 1.3 -84% 36.4 ± 3.2 1.8 ± 0 .1 -95 %
Philadelphia MSA 4.4 1.3 -71 % NA 2 .3 ± 0.2 NA
Tampa Bay MSA 1.3 0 .2 -87% NA 2 .3 ± 0 .3 NA
Detroit MSA 2.5 0 .5 -79% NA 2 .2 ±0 .2 NA
Dallas MSA 1.8 0 .5 -70% 842 .9 ± 124.5 0 .9 ± 0 .1 -99.9 %
St. Louis MSA 2 .3 0 .7 -70% 10 .3 ± 0.9 2.4 ± 0.4 -77 %
DenverMSA l.2 0.0 -97 % NA 2 .2 ± 0 .3 NA
Los Angeles MSA 5 .6 1.1 -8 1% 7 .7 ± 0 .5 2 .3 ±0 .5 -70 %
Seattle MSA l.5 0 .1 -91 % NA 0.8±0.1 NA
Table 4h. Toluene Emission (tpy) and Concentration (µg/m 3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Boston MSA 18 ,000 6 ,200 -66 % 9.2 ± 1.6 3.7 ± 0.4 -60 %
NewYorkMSA 57 ,000 28 ,000 -50 % 12 .1 ± 0 .7 4 .8 ± 0 .3 -61 %
Philadelphia MSA 25 ,000 7 ,600 -70 % 12.0 ± 1.6 3.4 ± 0.3 -72 %
Tampa Bay MSA 9 ,700 6 ,300 -35 % NA NA NA
Detroit MSA 2 5,100 12 ,000 -53 % 7 .9± 0 .9 5 .3 ±0.6 -33 %
Dallas MSA 24 ,000 9 .000 -63 % 3 .2 ±0.5 1.7 ± 0 .2 -47%
St. Louis MSA 14,000 6 ,500 -53 % 4 .5 ± 1.2 3.6 ± 0 .3 -21 %
DenverMSA 8,300 5,200 -37 % NA 8.4 ± 1.3 NA
Los Angeles MSA 54 ,000 17 ,000 -68 % 24 .3 ± 2 .0 8 .9 ± 0 .3 -64 %
Seattle MSA 16 ,000 11 ,000 -36% NA NA NA
Table 4i. Total Xylenes Emission (tpy) and Concentration (µg/m 3) Comparison
% Change 1990-1994 2002-2003
1990 2002 in Average Average % Change in
MSA Emissions Emissions Emissions Concentration Concentration Concentration
Boston MSA 11 ,000 4,300 -60% 9 .3 ±2 .2 0 .5 ± 0 .1 -94 %
NewYorkMSA 35 ,000 25,000 -29% 2.1 ±0 .1 0 .8 ±0.1 -63 %
Philadelphia MSA 15 ,000 5,200 -66% 6 .8 ± 0.7 0 .7 ± 0.1 -89 %
Tampa Bay MSA 6 ,200 4 ,300 -30 % NA NA NA
Detroit MSA 15 ,000 7,800 -50 % 1.8 ± 0.2 I.I± 0.2 -38 %
Dallas MSA 15 ,000 9 ,500 -36% 0 .9±0.1 0 .3 ±0.1 -70 %
St. Louis MSA 9,000 4,600 -49% 12 .9 ± 6.4 1.5 ± 0 .2 -89 %
DenverMSA 5 ,400 3 ,200 -41 % NA 2 .2 ± 0.3 NA
Los Angeles MSA 33,000 8 ,800 -73 % 19.8± 2.1 5 .2 ± 0.4 -74%
Seattle MSA 9 ,100 6,900 -25 % NA NA NA
\
'
\
\ I
Lea 'A"!Je;':\ CA ~ f"
-'T ' r>
I
/ _____ f-
l
Denver, C:O MSA / ... -
--,
a I.OlC -c::=--==-----=====-----~,,., 12S SJ 7:/J
' r a 111p.:,..st P!!tet'Sb L~"1SA
Figure 1. Metropolitan Statistical Areas In This Study
Each MSA represents an EPA Region. The Boston, New York C ity , Philadelphia, Tampa , Detroit, and St. Louis MSAs are all participants in EPA's 2004 Urban Air Toxics
Monitoring Program.
Boston-Cambridge-Qu incy, MA-NH MSA Average Annual Acetaldehyde Concentrations (1990-2003)
40
~~~y
35 +------------i---H--.;.....-------...;..--+--.-------~~~---l
30 -t--------.;.....--.;--..;...;-------------;--:-------------;~-1------l
;;,E 25 +----------------~-------~----------.;--,<-+-'----l
! !/ ~ 20 +--------~---!--~-----------+-~~------~--+-~---l ! l 8 15 +--------------i-----!.---!.--.;.....-------...;..--+--!--------1+--'~----l
10 +-------...;..--..;.---:-.;..--~-------...;_-.;..-..;.._ __ --IT7"/'----,H ---I
5 -~~---"--C---,,L-/1---------.;..--------l .., L: " . ......., _____ __,-=-_..,;Yii'I'= ~ T
0-1-----~-----~----------'----~-----~----------l
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Figure 2. Bo ston MSA Aceta ld e hyde Regulation Impact Anal ys is
After the implementation ofRFG Phase II (graph key = I) and the POTW MACT (graph key = 4), aceta ldehyde
concentrations appeared to have increased in the Boston MSA.
Boston-Cambridge-Quincy, MA-NH MSA Average Annua l Formaldehyde Concentrations (1990-2003)
30 ,--------------------------------------~
25 +----------!---!---!--!---.;~--------!---!-----'!-----+-----+--+-~
20
;;,
E a
2.
C
.2 15 f c ..
" C
0 u
10
• ., .., • ..,
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Yea,
Figure 3. Boston MSA Formaldehyde Regulation Impact A nal ysis
Formaldehyde concentratio ns in the Boston MSA were steady throughout the 1990s . After the implementation of the Large
Municipa l Waste Combustors MACT (graph key= M) and POTW MACT (graph key= 4), conce ntrations appeared to have
increa se d.
;;,
New York-Northern New Jersey-Long Island, NY-NJ-PA MSA Average Annual Benzene Concentrations
(1990-2003) 5------------------'----------------------~
[:] ~ ~ ~ CJ ~lw·TTjTF H,q ~ ..
. . . . 4 +---------------.-----------------.---------.-i----------i-e------------i
-E 3 +---------...... --~----.------------.--~-------~---~ "' 3-
c:
0
~ c ..
~2 +---------.----------i-----------i--------.---~--~-----~~--~
0 u
o +--------"'"·---'·---·---·---·---·--·~~i __ i_._· -----~·-·~---<
1990 1991 1992 1993 1994 1995 199 6 1997 1998 1999 2000 2001 2002 2003
Year
Figure 4. New York City MSA Benzene Regulation Impact A nal ys is
Benzene concentrations in the New York MSA appeared to have decreased after implementation of mobile source rules:
winte r-oxygenated fue l (graph keys= a-c) and reformulated gasoline (graph key= d). Rules targeting stationary sources did
not appear to reduce benzene concentrations.
.:;
50
New York-Northern New Jersey-Long Island, NY-NJ-PA MSA Average Annual Mercury Compound
Concentrations (1990-2003)
------------·····-·····-···-······-············------···-··-·------------·
~ ~ ~ ~ ~ ~lw:l~I ~ cij
: !
~ I
40 +--------+--.---....---.,.....----i---+--+1P<-i------i-----1:-------!------i· I
-E 30 +-------~-.----s----~-+---t--~------.,.....~-------~------r-1
"' ..:.
C:
0 .,
£:
C: ..
" c: 20 +--------~--~---+---~-----~--!--!--+-~-----+---....---+-;
0 u
10 ;--------~----------------~-----+-....... -----~---
0 +---------·~·---·---·~· ---·---·---·~· --"-"~·---·---·------"----;".
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Figure 5. New York City MSA Mercury Regulation Impact A nalysis
Mercury co nce ntrati ons appeared to have decreased after implementation of the Petroleum Refineries MACT
(graph key= w), Reformulated Gasoline Phase II program (graph key = I), and the Large Municipa l Wa ste
Combustors MACT (graph key = M).
e
Philadelphia-Camden-Wilmington, PA-NJ -DE-MD MSAAverage Annual Cadmium Compound
Concentrations (1990 -2003)
8
E4 +------------------------~--_,__ _ _,_--__ ...,.. __ .........,
C
0
~ c t 3+-----------------------------~,--+-------------<
C
0
<)
• • • • ;.
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
Year
Figure 6. Philadelphia MSA Cadmium Compounds Regulation Impact Analysis
•
2003
Cadmium compound concentrations appeared to have increased throughout the study period in the Philadelphia MSA,
however, limited or no data is available from 1998-2000 .
1500
1350
1200
10 50
;;,
E 900 a .:.
C:
0 750 ~
" u 600 C:
0
<)
450
300
150
1990
Ph iladelphia-Camden-Wilmington , PA-NJ-OE-MD MSAAverage Annual Lead Compound
Concentrations (1990-2003)
1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 200 1
Year
2002
Figure 7. Philadelphia MSA Lead Compounds Regulation Impact Analysis
2003
Lead compound concentratio ns appeared to have decreased substantially after implementation of the Secondary Lead Smelter
MACT (grap h key= u) and the Gaso lin e Distribution Stage I MACT (graph key= t).
.;-
Tampa-St. Petersburg-Clearwater, FL MSA Average Annual Lead Compound Concentrations
(1990-2003)
1500 -----------··------------·-··----.. ----··--·---······-····-.... ·-··--.. ----.. -· .. ·-·--·--·--.. -·-·-·--------.. --.. ----··-----------~
v 1 3 1
1350 +------+-------------~------------------~~-~--,
1200 +------+---------------------e----------..,.....------.--r-r---1
1050 +------+-\------------~------r---------...-----~ ..... -.-------1
"§, 900 +------+--+--+----------T---------------------------1
.S
c
,g 750 +--------\1----------+-~-+-----c,.-Ll\--,----------,----~-,..-:---J
I!
C:
~ C 600 +--------t---....-------1--+-~-+---~ ........ ------------~~-~--,
0
(.)
• • • 0 +--------------------~---------------------1
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 200 1 2002 2003
Year
Figure 8. Tampa MSA Lead Regulation Impact Analysis
Lead compound concentrations appeared to ha ve decrea se d overall during the study period, most notabl y after th e Secondary
Lead Smelting MACT (graph key= u).
Tampa-St. Petersburg-Clearwater, FL MSA Average Annual Toluene Concentrations
(1990-2003) 8,-----------------------------------------,
6 +------------------....p.._.+--+--+-+--t-'-+--+--------+-'t-----,
~:
1 '--+-
.;-5 +--------------------~~~~~~-=~--------~=---~
I \i ~4 +-------------------------~--------------~
I 1 83+-----------~~]\: -~
2+----------+----~\ .----+--+------I
r
t t 0 +-----------------------------------------1
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Figure 9. Tampa MSA Toluene Regulation Impact Analysis
Limited toluene data in the Tampa MSA for the la st fi ve years limits the conclusion that concentrations are continuing to
decrease.
Detroit-Warren-Livonia , Ml MSA Average Annual Lead Compounds Concentrations (1990-2003)
36 .--------------------------------------~
igl Ill fril I v I 3 I 71
32 +--l-------,-----------'L:J'==;::=. __ -----==L.J:;=-____ ___c:LJ:=:;=..._----=· :::;=;::· =·::;::::=.·___j
28 t--t-~"c-----j---f-----,.--------t----------'----~_;_--'---l
~/\ I 24 +----¥---~\-+--V-+-"'~= ,,,-+-V~~------"F-._;__: ~.:..______;____
.E. 20 +-----------f--....1..1_ ""-"d:,,-"',,.,,'.j.-+--+---!-----~==--1"~t---l----i'-+---';.__-1
g f'--~ 1 ~ . .
] 16 +----------+-----~-+-------.--------+=-+---".di"-i--:-..---i
u
C
0 u
12 t----------------_;_ ____ __; ________ .;_ ___ ..;_.;......--:---1
8 +------------------------------------_;_--1
4 t------------------!-----~--------~---~~~--I
0 +-----------------·------·--------~·----•-• __ •:.._--1
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Figure 10 . Detroit MSA Lead Regulation Impact Anal ys is
Lead co nce ntrati ons in Detroit a pp eared to have dec reased stead ily duri ng the stud y pe ri od . The biggest affect ap pears to be
th e implementati on of the La rge M un ic ipal Was te Com bustors MACT (grap h key = M).
Detroit-Warren-Livonia, Ml MSA Average Annual Xylenes (m-,p-,o-) Concentrations (1990-2003)
4 -----------------··----·------
~ 1r,s,tl~ EJ ~ EE]
3.5 +--------+-----------~----~-~~-~--~----~~----l
3 t-----,,----t----------+-------+---+--+---+----+-----+-----l
f 25 t-----t---t----------+-------:----:---:----:-----:-----+-;......---l
.;,
-=-I\ ~ I \ ]2----~~\---T----------------~
8 1 .5 -t---t---\--\T-~-+----+--~~: -~~: ~: :~; ~_----,...-t~ yi ---1---l•
r I 1
0 .5 +------------------i---------:----:---:----:-----:------i---;......---l
o+----------------------------------------1
1990 199 1 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Figure 11. Detroit MSA Xylen es (total) Regulation Impact A nal ysis
Although total xy lene co nce nt ra ti o ns had littl e va ri a nce thro ughout the 1990s , it's uns ur e how statio nary sou rc e rul es affec ted
xyle ne co nce ntr ations du e to the limi te d data ava il a bili ty of xy lene measure me nt s fro m 199 7-2000 , when several regul ation s
we re imp leme nt ed .
Dallas-Fort Worth-Arlington , TX MSA Average Annual Benzene Concentrations (1990-2003)
3.5
~ QJ [§IX l•,AICIE I I I KI IY,0,11 4 I
3
2 .5
.;-
E
g) 2 2.
C
0 ;
J;
C .. 1.5 u
C
0
(.)
0 .5
... ... ... ...... ...... ... ... ...
0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Figure 12. Dallas MSA Ben ze ne Regulation Impact Analysis
Benzene concentrations in Dallas show a downward trend , apparent ly in response to implementation of Tier 1 Mobile
Standards (graph key= j).
Dallas-Fort Worth-Arlington , TX MSA Average Annual Mercury Compound Concentrations (1990-2003)
1400
1200 ~ ~ ~ [!]
1000
.;-~ V \ E ;;, 800 ..:. \ V \ C
0
~
C
600 ..
j \ u
C
0 ~ (.)
400
\ 200 :
)-T I ~ I l
i ... ...
0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 200 1 2002 2003
Year
Figure 13. Dallas MSA Mercury Regulation Impact A nal ysis
Mercury compou nd concentrations appea r to have decrease substantially with the implementation of the R efo rmulated
Gasoline Phase I Program (graph key= d). However, according to the NEI, mercury emissions from Hazardous
Waste Combustors decreased by 97% from 1996 to 2002 for this MSA, most I ikely as a result of impending
regulations (grap h key= 8).
St. Louis , MO-IL MSA Average Annual Cadmium Compound Concentrations (1990-2003)
45
40 d
35
30
;;,
E
Cl
.:. 25
C:
0
~
'E 20 "' u
C:
0
(.)
15
• 0-1-------~----------~--~----~----------~----<
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 200 1 2002 2003
Year
Figure 14. St. Louis MSA Cadmium Regulation Impact Analysis
Overall , cadmium compound concentratio ns in the St. Louis MSA appeared to have decreased during the study period . The
implementation of the Reformulated Gaso line Phase 2 Program (graph key = I) and the Primary Lead Sme ltin g MACT
(graph key = P) coincide with these reductions. However, no impl emented regulations exp lain the increases in the 1996,
1997 , a nd 1999 concentrations .
27
24
2 1
18
;;,
t
.:. 15
C: _g
I!
'E 12 "' u
C:
0
(.)
9
6
3
0
1990
St. Louis , MO-IL MSA Average Annual Xylenes (m-,p-,o-) Concentrations (1990-2003)
I"-,-.._:
•
199 1 1992 199 3 1994 1995 1996
Year
••
1997
·x··· . . .. . . . .. . . . . . . . .. . . . . . . . . . ..
1998 1999 2000 2001
I o.11 41 s 1
2002 2003
Figure 15. St. Louis MSA Xy lene s (total) Regulation Impact Analysis
Total xy lene concentrations in the St. Louis MSA declined dramatica ll y from 1990 to 2003 , apparently in response to several
implemented statio nary and mobi le source regulations targeting VOCs (grap h keys= d, p, r, t, w, x, z, A-C , E, F, I, Q).
However, lack of xy lene measurements between 1995 and 2000 limit the certainty of th ese conc lusio ns.
Denver-Aurora, CO MSA Average Annual Acetaldehyde Concentrations (1990 -2003)
6
~ ~ ~ ~~ [£1 ly,z,AI~ ~ ~ ~ ~
I
\\ 1 I
\r • !
: i
I : lN
: ' 11 I
I
11
I : I • • • • • • • • • 'f • " • • 'f i
0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Fi g ure 16. Den ve r MSA Acetaldehyde Regulation Impact Analysis
Over the last four years, acetaldehyde co ncentrations appeared to have decreased after implementation of mob il e source
rules : winter-oxygenated fuel program (graph keys= L, S, 5) and the National Low Emissions Vehicle Program Phase II
(graph key = K).
Denver-Aurora, CO MSA Average Annual Cadmium Compound Concentrations (1990-2003)
72
~ ~ ~ ~ ~ ~
64
0 ~ ~ ~ ~ ~
56
48
;;,
E ;;,
.S 40
i::
0
~ c 32 " " i::
0
0
24
16
/\
I \!
I \
I !\
/ \
8
0
N
"L. ~ -. .
~ -. . .i --. . -T ~ -h ... ... ... ... ... ... ... i ... ~ ... -... ;
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Figure 17. Den ver MSA Cadmium Regulation Impact Analysis
No implemented sta ti onary source regulations we re identified in the Denver MSA which apparentl y affected cadmium
concentrations . According to TRI, cadmium emissions from Asarco , Inc . G lobe Plant decreased from 0 .198 tpy in 1990 to
0 .077 tpy in 1994 , a 61 % decrease . Cadmium em iss ions remained steady for this plant through the 2002 NEI.
;;;
Lo s Angele s-Long Beach-Santa Ana , CA MSA Average Annual Ethylbe nzene Concentrati ons
(1990-2003) 7,---------------------------------------~
~ [!] ~ [:] I I p I q,r,t I w ,x II y,z,AI E,F I H,11 ~ I s I 1 1 4 ,5 1 719 1, . : ..
• I
: I
6 +-----+--------.----~--~-----.---~~----;----.---...;---~~-.;......;-__..;_i
! I
5 +--!-----------!------.------i-----~--;.......-+-~;.......~~;.......-----:---~--~-----:-~~-; I
: i : I
E
}4 +---+--.,..--=---1-"r---~--~-----i-----;__~-;__~-;__--i--...;_--~~-.;...._;__
: i
: i
: i C
0 .,
i!
: I
: I
c B 3 -l----...l..-----+-~::;:__-J---~"'-<.-~--;.._---i----;.._-----:c--;.._~-~--+---~~'---+--
I I
c
0
0
• !
: i
: !
1 !
: !
• I
i I
• t t • • • • ... • t • • t • • · 1 t , • 0+-----------~-------------------~--------
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 20 03
Ye ar
Fig ure 18. Lo s Angeles MSA Et hylb enze ne Regul ation Imp act Analys is
Ethylbenzene concentrations in the Los Ange les MSA appeared to have declined steadily in response to several imp lemented
stationary and mobi le source regu lations targeting VOCs (graph keys = a-L).
Los Angele s-Long Beach-S anta Ana , CA MSA Ave rage Annual Formaldehyde Concentrati ons
9 ,------------------'-(1_9_9_0-_2_00_3.:_) _________________ ~
7 +---------+---+---+---+---c----+-+--+--+-:--!----,-.....-~-+--+-~-~
2 +---------+-----------~---+---a---+-~ ........ ~-~~---l----.---!------:!-1
t t tttit ttt titt o-l--------~------------------------------....J t t t t
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Figur e 19. Los Angeles MSA Fo rm ald e hyde Regulation Imp act Analy si s
Forma ldehyde co ncentrations have steadi ly increased during the study period . T h is is most li ke ly due to the imp leme ntatio n
of the R eformu lated Gasoline Phase I Program (graph key= d).
Seattle -Tacoma-Bellevue, WA MSA Average Annual Formaldehyde Con centratio ns (1990-2003)
~ ~ ~ [:JQJ [:] I X I z,AI E I ~ El ~ I
I
I
I
4
;:,
t
2.
C i 3
I! c ..
" C
0
0
2
I
I I
I
V I
I ir-1 · I . . . .
I
. . . . . . . . . . . . I . . i
I
i
I • " " " " 'Y " " " " " " I
! 0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Fig ure 20. Seattle MSA Fo rm ald e hyde Regul atio n Imp act A nalys is
Ov er the last three yea rs , forma ldehyde concentrations have appeared to hav e increase d , noticeab ly after the imp lementation
of th e Publicl y Owned Treatment Works MACT (grap h key= 4). Howeve r, formalde hyde data prior to 2001 is limited or
unavailable , thus making it diffi c u lt to characterize a trend.
Seattle-Tacoma-Bellevue, WA MSA Average Annual Lead Compound Concentra ti ons (1990-2003)
32 5
300 1-------1 w ,x t---------1
27 5
250
225
w 200
Cl
E..
C 175
~
I! 150 c
" " C 125 0
0
100
75
50
25
• 0 • • ..
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Fig ure 2 1. Seattle MSA Le ad Regulatio n Imp act Ana lys is
During the study period, lead concentrations app eared to hav e decrease d. After implementatio n of the Petroleum Refine ri es
and Aerospace Manufacturing MAC T s (g raph ke ys= wand x, re s pectively), concentrations decrease d sub stantia ll y.
Intere stingly, lead concentrations apparent ly increased after the prohibition ofleaded gaso lin e (graph ke y= g).
-
-
-
-
-ERG RESPONSE TO
-CITY OF FORT
.. WORTH'S FORMAL -
QUESTIONS
ERG Response to City of Fort Worth's Formal Questions
As part of the requirements outlined in the Request for Qualifications, the ERG Team is providing
written responses to eight questions posed by the City of Fort Worth. We understand that answers to
our questions will be considered by the Committee as part of the selection process.
Below, we re-state the question (in bold italics), followed by our written response (normal typeface).
Thank you for the opportunity of considering the ERG Team to provide technical support in this air
quality study . We will be happy to elaborate on any responses during the interview. To aid in your
review, we have added a list of abbreviated terms below.
Abbreviations
AERMOD
AMS
API
ATSDR
cfm
CFR
CV
DQI
EPA
ERG
FB
FLIR
H2S
HAP
HRVOC
IR
kg/hr
km
lb/hr
MDL
M/WBE
NATA
NCTR
NOx
PM
ppm
QAPP
REL
RFQ
RHC
RPD
scf
TCEQ
TO
TRC
TVA
voe
June 24, 2010
AMS/EPA Regulatory Model
American Meteorological Society
American Petroleum Institute
Agency for Toxic Substances and Disease Registry
cubic feet per minute
Code of Federal Regulations
Coefficient of Variation
Data Quality Indicators
Environmental Protection Agency
Eastern Research Group
Fractional Bias
Forward-Looking Infrared Camera
Hydrogen sulfide
Hazardous air pollutant
Highly-reactive volatile organic compound
Infrared
kilogram per hour
kilometer
pound per hour
Method Detection Limit
Minority and Women Business Enterprises
National-scale Air Toxics Assessment
North Central Texas Regional
Oxides of Nitrogen
Particulate Matter
parts per million
Quality A ssurance Project Plan
Relative Exposure Limit
Request for Qualifications
Robust Highest Concentrations
Relative Percent Difference
standard cubic feet
Texas Commission on Environmental Quality
Toxic Organic
Texas Railroad Commission
Toxic Vapor Analyzer
Volatile Organic Compound
Page 1 of 14
ERG Response to City of Fort Worth's Formal Questions
Question 1 -How does your proposed study take one hour or instantaneous measurements into
account versus various exposure levels over a 24 hour period or longer? Will your testing include
FLIR cameras? If so how? Please list each type of sampling proposed and the impact that it is
designed to assess .
Disparate Time Measurements (instantaneou s or I-hour v s. 24-hour period or longer)
ERG is experienced in comparing di sparate measurements to various expo sure level s. It is important to
properly compare an exposure level to a concentration value or average at the same time period . For
example , it is not appropriate to compare a 24-hour (short-term) concentration to a chronic (long-term)
expo sure le v el , and v ice versa . We have demonstrated this capability and understanding of di sparate
time measurements in our work for EPA 's Air To xics Data Analysis project. In this project, we
compiled an archi ve of over 26 million hazardous air pollutant (HAP) records , spanning 30+ years
across the entire United States . This archive consisted of several types of time-period measurements
(I-hour, 3-hour, 4-hour, 6-hour, 12-hour, and 24-hour), and ERG was tasked with evaluating each HAP
against their re spective exposure levels. Typically, most exposure levels are 24-hour (daily) in nature ,
but some HAPs also hav e sub-daily exposure levels . For example , benzene has a Relative Expo sure
Level (REL) over a time-period of six hours. In this situation, we were able to average six I-hour
concentrations or two 3-hour concentrations to accompany any si x -hour data measurements in the
archive , and de velop a frequency in which the six-hour benzene average wa s greater than its REL.
Howev er, most s hort-term or acute exposure le vels are 24-hours. In the above work for EPA, we
required that to be considered a valid 24-hour average, at least 18 of the 24 hours must have a valid
measurement. Thus , a valid 24-hour measurement could be comprised of at least eighteen I-hour
measurements, six 3-hour measurements, fi ve 4-hour measurements, three 6-hour measurements , or
two 12-hour measurements. In the proposed study, we would work with the City to determine if this
approach , or a modified approach would meet their needs .
Another time-period that the City may want to consider would be monthly , seasonal, and/or quarterly
averages. These av erages could then be compared to interm ediate-term exposure levels (typically over
periods from 15-days to 364 days). Finally, annual averages can be de v eloped by averaging a
minimum number of monthly, seasonal, or quarterly averages. These av erages can be compared to
chronic exposure levels .
Currently, we are supporting the data analyses component ofEPA's Schools Air Toxics Initiative .
Daily (24-hour) concentration values are compared to sample screening levels (i.e., the level at which
significant risk is observed for short-term exposure), and estimated long-term concentration averages
are compared to long-term comparison levels, such a s for cancer and/or noncancer effects.
FLIR Cameras
Yes , our testing will include FLIR cameras . The ERG/Sage team believes that it is important that all
potential point sources be screened via the FLIR camera for several reasons: I) if this is not done , the
community will be dissatisfied over what will be perceiv ed as an incomplete effort, 2) homeowners
affected by un-sampled sources will ask why "their'' neighborhood was not tested , and 3) the point
source results will have a direct impact on the ambient air and modeling efforts so it is critical that they
be as inclusive as possible.
Because the number of potential sources is large (approx imately 1,600 wells , perhaps a hundred
June 24 , 2010 Page 2 of 14
ERG Response to City of Fort Worth's Formal Questions
compressor stations, several gas processing facilities and many miles of gas pipelines), it will be
necessary to quickly distinguish the bad actors from the good . The IR camera is ideally suited for this
purpose. Large numbers of equipment can be quickly surveyed by the camera to detect dangerous
leaks. Using the IR camera, investigators can screen well pads in a matter of minutes ; small compressor
stations in under half an hour; and medium sized gas conditioning facilities ( containing dehydrators,
storage tanks, compressors, piping and incinerators) in less than 4 hours.
The only exception to the 100% screening practice will be gas pipelines. Because the pipelines are
relatively new and contain no external moving parts, they pose the lowest risk of leakage among the
identified point sources. Given time and resource concerns, we feel the interests of the project will be
best served by visiting a percentage of accessible pipelines with the IR camera once the other sources
have been surveyed.
Currently we plan to field two IR Camera teams for this project. Each camera team will be equipped
with a Toxic Vapor Analyzer (TVA) to perform Method 21 screening on selected natural gas service
components. All point source measurements will be instantaneous. The IR camera will quickly detect
the large leaks(> 10,000 ppm) that can present safety and health concerns . The TVA is much more
sensitive and can detect very small hydrocarbon leaks that will not be seen by the camera.
June 24 , 2010 P age 3 of 14
E R G Response to City of Fort Worth's Formal Questions
Question 2 -The first bullet and section A of the Scope of Services description in the RFQ describes
the City's desire to quantify actual emissions being released from sources involved in natural gas
operations. In 1 page or less, please summarize your firm's proposed approach to collect the data
sought in A.I) and A.2) of the desired Scope of Services. (This response may refer to information
presented in your firm's qualifications package.) As part of this discussion, please describe what
specific pollutants will be quantified under this task of the project and what units will be used to
quantify emissions released (e.g., lb/hr, sci, etc.).
Point Source Type Emissio n Rate Determination
Wells Selected equipment leaks found with the IR camera will be sampled with
the High-Flo® Sampler to determine emission rates as methane in cfm.
Canister samples will be collected from selected leaks to obtain
hydrocarbon-speciated (VOCs, HAPs, and HRVOC) leak rates (kg/hr).
Valves, Connectors at Leaks detected by the IR camera of valves and connectors will be
Compressor Station sampled with the High-Flo® Sampler to determine emission rates as
and Gas Processing methane in cfm. Canister samples will be collected from selected
Facilities equipment leaks to obtain hydrocarbon-speciated (VOCs, HAPs, and
HRVOC) leak rates (kg/hr).
Emission data will also be collected with the High-Flo® Sampler (cfm)
from selected non-leaking equipment and equipment leaking below the
detection limit of the IR camera (<10 ,000 ppm).
Compressors Compressor leaks detected by the IR camera leaks will be sampled with
the High-Flo® Sampler to determine emission rates as methane in cfm if
the leak area is accessible . Canister samples will be collected from
selected vent leaks to obtain hydrocarbon-speciated (VOCs, HAPs, and
HRVOC) leak rates . A subset of safely accessible compressor vents will
be tested for NOx and H2 S emissions using a portable combustible gas
detector and portable flow measurement devices (kg/hr).
Storage Tanks and Leaks detected by the IR camera from tank hatch covers, pressure relief
Dehydrator Vents devices, and still vents will be sampled with the High-Flo® Sampler if
accessible, to determine emission rates as methane in cfm. Canister
samples will be collected to obtain hydrocarbon-speciated (VOCs, HAPs,
and HRVOC) leak rates (kg/hr).
Gas Transmission Emissions from natural gas transmission line leaks found by the IR
Lines camera will be measured with the High-Flo® Sampler (cfm). Canister
samples will be collected from a selection of gas line leaks to obtain
hydrocarbon-speciated (VOCs, HAPs, and HRVOC) leak rates (kg/hr).
June 24 , 2010 Page 4 of 14
ERG Response to City of Fort Worth's Formal Questions
Question 3 -Which air dispersion models are you proposing to utilize for this study and why? How
many data points are required to model atmospheric dispersion to ensure that the results are
statistically significant?
Dispersion Model Selection
While we have demonstrated capability in a number of dispersion models, we believe only one model
is necessary for this analysis, AERMOD (AMS/EPA Regulatory Model). This is based on the
following reasons:
a) AERMOD is U.S. EPA preferred air dispersion model for near-field (Appendix W to 40 CFR
Part 51 , Guide lin e on Air Quality Models,
http://www .epa .gov/ttn/scram/guidance/guide/appw 05 .pdf, Page 68253);
b) AERMOD is widely accepted and used in the scientific and regulatory community;
c) The study domain falls within the distance limits of AERMOD (50 km or -30 miles)
d) AERMOD supports multiple source types (vents, stacks, area sources for piping)
e) Special meteorological circumstances are not at issue in this case ( complex wind flows ,
stagnation, complex terrain); therefore, alternate models, such as CALPUFF, are unnecessary;
f) AERMOD needs only a single meteorological station, along with upper air data to execute,
unlike grid models ; and,
g) Ozone modeling is too costly and is evaluated on a regional level; thus, it is not considered part
of the work scope.
Data Points
We interpret data points, in this context, to mean simultaneous observations of air quality data a°:d
meteorological observations. The number of observations, although important, is not the critical issue.
The priority is having air quality and meteorological data taken immediately downwind of the emission
sources. This requires well-sited air quality instruments.
That said, we consider 25 or more downwind observations from at least one monitor in the area to be
ideal. This is based on the number of observations used to calculate the.frac tional bias. Fractional bias
is a statistic used to evaluate general model performance. The general expression for the fractional bias
(FB) is given by:
FB = 2 (PR-OB)
(PR+OB)
OB and PR refer to the averages of the observed (OB) and predicted (PR) highest 25 values. The same
expression is used to calculate the FB of the standard deviation where OB refers to the standard
deviation of the 25 highest observed values and PR refers to the standard deviation of the 25 highest
predicted values . In addition to the average and standard deviation, the fractional bias can be
determined based on the 25 largest values, the robust highest concentrations (RHC). Negative values
denote over-prediction and positive values denote under-prediction. A value of+/-0.67 denotes model
predictions off by a factor of 2.
June 24, 2010 Page 5 of 14
ERG Response to City of Fort Worth's Formal Questions
Question 4 -Pursuant to the Request for Qualifications, a goal of 10% utilization for minority and
women business enterprises (MIWBE) has been established for this projecl As a reminder,
MIWBEs must be registered by the North Central Texas Regional Certification Agency and must be
located in the marketplace or doing business in the marketplace at the time of bid opening or during
negotiations related to proposals. Please clarify your proposed MIWBE subcontractor and the
proposed parts of the proposed work plan that they are anticipated to complete.
ERG and Sage will be using the services of Hicks & Company to assist in the point source testing ,
ambient air sampling, and communication and outreach ta sks. Hicks & Company is registered as a
minority and women busines s enterprises (M/WBE) by the North Central Texas Regional (NCTR)
Certification Agency, and i s currently doing business in the Fort Worth metropolitan area. Hicks &
Company is currently providing environmental management and compliance support for the State
Highway 161 and North Tarrant Express transportation projects.
Specifically, we will u se Hicks & Company personnel as field technicians in the point source IR
camera surveys , Method 2 1 screening, and canister collection activities , as well as for communication
and outreach activ ities once data collection and data analysis hav e been completed. Hicks & Company
personnel are experts in the community education and awareness area, and have presented training on
this subject the USA, England, and Africa. We are attaching Hicks & Company 's NCTR certification.
NCTRCA
Women -Owned Business E nterpris e Cer tification
June 24 , 2010
.Hicks & Company Envir o A.r che ological Co nsul tants
Woman-Owned Business Enterprise
ba, l!fod wilh lht A&<""Y •n Amda'rii"' ddlned by ~ NCTRCA M/Wlll! polkw & pm«du ,... •IMI I! hmobt «riified to
provldt 11trvl<t{s) In I.ht follo..toc areas:
541710 , 541G10 : 541618 ; 924110 ;
Research and Development in the Ph ysica l, Englneenng , and life Sciences, Marketing
Research and Public Opin ion Poling: Other Management Consulting ~,vices:
This Certili<aflon Is valid beglnnin June 201 O ;rod superseded any registration or Lbtlllg
previously Issued. Th.ls eerllllcation mu,,i be updated allllnltlly by sub niis!ilon or ~n Annual Update Affidavtt. At any tlme
there Is a t!lwlge In ownership or conu,,1 ul the llrm, uotlfl cati<m must be madt immediately h> the Nnrtlt Ccnt:rnl Teiu1.1
R<>glonal Culif"iC•lfon Al(ftlcy.
Certificate tltp lra.tlon _ _..::J.c.:\Jn.:.::ce ______ ~W_1_1 _
Cerllncutkm Ad minislra tor
Issued date June ___ ,20_10_
CERTJ}'ICA'.JION NO. WFWB4 5539Y0611
Page 6 of 14
ERG Response to City of Fort Worth's Formal Questions
Question 5 -The study scope includes anticipating emissions from full build out of the Barnett Shale
in the City of Fort Worth. How do you intend to go about defining the baseline condition as well as
determining what full build out would encompass? Please discuss total number of pad sites, well
heads, and production rates as well the sources for information to be used to formulate your
response.
Since the point source sampling effort will be surveying all potential leak sources with the IR camera
and determining emission rates from most of the leaks found, it is expected that sufficient emission
data will be collected to develop average emission factors for the following point sources:
• Wet Gas Wells
• Dry Gas Wells
• Wet Gas Compressor Station Valves
• Dry Gas Compressor Station Valves
• Wet Gas Compressor Station Connectors
• Dry Gas Compressor Station Connectors
• Wet Gas Compressors
• Dry Gas Compressors
• Storage Tanks
• Glycol Dehydrators Stations
• Wet Gas Transmission Lines
• Dry Gas Transmission Lines
Applying these emission factors to the estimated quantities of full build out equipment types and
services should provide a reasonable estimate of potential future emissions. The total number of pad
sites, well heads, and current production rates can be obtained from the Texas Railroad Commission
(TRC) database . Recently, TCEQ has developed a comprehensive equipment-level inventory of all oil
and natural gas source types in the Barnett Shale, which includes Tarrant County. This data is
anticipated to be publically available.
Anticipated future activity will be obtained from energy statistics available through the US Energy
Information Administration, or from drilling and production projections from trade groups or other
available resources such as Baker Hughes. Additionally, surveys of the owners and operators can be
used to augment future activity for the full build-out. The ERG Team is experienced in preparing,
coordinating, and distributing surveys of this nature, especially within the State of Texas.
June 24, 2010 Page 7 of 14
ERG Response to City of Fort Worth's Formal Questions
Question 6 -The biggest challenge in successfully completing this study is to convince a skeptical
public that this study is fair, objective and provides results that are credible. How will your project
plan accomplish this?
The ERG team has extensive experience working on projects where community members are very
concerned about local air pollution levels, yet are skeptical of studies that have attempted to
characterize air quality . We fully appreciate that a goal of this project is not only to provide the City of
Fort Worth a scientifically defensible assessment of air quality impacts from oil and gas production
activities , but also to ensure that the study results stand up to the scrutiny of any potential critics. If
awarded this task, the ERG team will work closely with City officials to develop an outreach and
communications plan designed to meet these goals.
While the extent of our proposed outreach and communications efforts will ultimately depend on
project resources and other considerations, we share below some guiding principles that typically factor
into our site-specific outreach and communications strategies.
Project Planning Phase : Build Trust
When proposing the most effective outreach and communications strategies , ERG first works with its
clients to determine exactly who is meant by "the community." This can be the public at large , specific
environmental groups or activists, elected officials, and others . ERG will work directly with City
officials to characterize the local community and understand their concerns , background, and
perceptions, which will help inform subsequent outreach activities . ERG will also consult with City
officials up front to determine who will be the "voice of the project" and under what circumstances the
contractor will be expected to communicate directly with community members and other interested
parties.
A key aspect to building trust is meeting directly with all stakeholders and interested parties. Should
project resources allow , ERG will encourage scheduling a few such meetings or public availability
sessions early in the project to introduce these community members to the scope of the project and the
project team and to solicit input on the proposed sampling and modeling protocols . Opening the lines
of communication at the earliest stages of the project helps provide community members a sense of
ownership in the future work and lets them know that their opinions and input are truly valued . It also
helps in setting realistic expectations .
The ERG team recognizes that community members sometimes have requests that go beyond the
intended scope of work for a project. However, our experience is that community members still
appreciate the opportunity to offer input, even if their specific recommendations cannot always be
adopted. During these initial communications, ERG will document the community members ' various
expectations of the project. Through consultation with City officials , we will ensure that community
members are fully aware of which expectations fall within the scope of the anticipated work.
Another aspect of building trust with the community is fully disclosing, from the project onset, the
ERG team 's past working relationships and describing our technical qualifications. During initial
meetings with community members and stakeholders, ERG will emphasize that we are a company that
works almost exclusively for public agencies, and rarely working for private industry. For more than 25
years , ERG has researched virtually every type of industrial air pollution source, including numerous
projects evaluating air quality impacts from oil and gas production activities. We therefore have
developed extensive technical expertise for the source of interest, but we have no financial or
June 24 , 2010 Page 8 of 14
ERG Response to City of Fort Worth's Formal Questions
professional ties to the oil and gas exploration industry.
We can also share with interested community members sample projects that demonstrate our
qualifications. For instance, EPA entrusts ERG's laboratory with conducting extremely high-profile
monitoring projects, including multiple nationwide programs and measuring air quality impacts in the
Gulf region following Hurricane Katrina and the recent oil spill. We can also describe the air
monitoring we conducted for the Agency for Toxic Substances and Disease Registry (ATSDR) that
revealed potential public health hazards associated with oil and gas exploration activity in Illinois. Our
monitoring projects with ATSDR are particularly notable because they often involved placing ambient
air monitoring equipment directly at community members' households-and sometimes inside their
households. These projects required very close coordination with community members. The ERG team
can provide these and many other examples of our work on high profile projects, with the intent of
assuring community members that we are well suited to help the City of Fort Worth answer its pressing
questions regarding local air quality.
Ultimately, the initial communications-which will follow the specifications in our outreach and
communications plan-are designed to build trust with the community. We fully appreciate that this
trust must be earned, not assumed, and that lack of trust has the potential to erode at the credibility of
our findings , no matter how scientifically defensible they may be. Our outreach and communications
specialists and technical staff all strive to build the necessary foundations with community members
such that they view our project team as a trusted source of information.
Project Implementation Plan: Maintain Trust
Throughout the testing and monitoring program, the ERG team will engage in additional outreach
activities to keep City officials and the community informed of progress and to maintain trust with all
interested parties.
First, we will ensure that we keep a strong, visible presence throughout the project; several options are
available for doing so, and the ERG team will work with City officials to determine which options best
suit their needs . Examples of these options include: holding periodic update meetings to keep interested
parties up-to-date on progress; launching a project website where we post weekly updates on field
activities and other important project milestones; and ensuring quick response to all information
requests from City officials. Through these and other options, we will communicate our continued
commitment to meet project goals and answer community questions.
Second, we will discuss with City officials options to have interested parties actually witness some of
ERG's field activities. This could be accomplished by giving people tours of the monitoring sites or
even allowing observers present at certain emission testing events , provided that activity does not
violate any aspects of our health and safety plan. We have found that allowing community members an
opportunity to see our work in progress can generate more trust and confidence in the overall process.
Finally, further options exist for demonstrating the credibility of our work. Our quality assurance
project plan will list the specific quality control approaches adopted, as well as identify specific data
quality objectives that must be met in terms of the accuracy and precision for various measurements.
Should City officials be interested in pursuing further means for demonstrating data validity, additional
options are available (e.g ., having an external group of independent experts review and comment on
draft products or sending duplicate samples to a competitor's laboratory to characterize measurement
accuracy) but these supplemental options involve additional costs that will have to be considered.
June 24, 2010 Page 9 of 14
ERG Response to City of Fort Worth's Formal Questions
Question 7 -In order to make defensible conclusions from the study that would apply city wide, a
significant number and variety of sites and sources distributed geographically will need to be
evaluated. How will the contractor balance the need to evaluate a significant number of sites and
sources with the short sampling window allotted for this study?
Ambient Air Monitoring
With respect to being able to make defensible conclus ions based on the ambient monitoring data, two
separate but distinct questions must be considered:
1) Is the data itself appropriate to the study objectiv es and defensible?
2) is the data representativ e of the study area .
Con s ideration #1 . I s the data itself appropr iate to th e s tudy objectives and defens ible?
For measurement of Air Toxics and Carbonyl compounds, ERG 's procedure for performing sampling
and analysis are appropriate for the envisioned survey. Our procedures are conducted in strict
accordance with the guidelines detailed in EPA Compendium of Methods T0-15 and T0-1 lA, which
ERG was instrumental in dev eloping for EPA and in accordance with the quality specifications
presented in our Category 1 EPA Approved Quality Assurance Project Plan (QAPP) for the EPA
National Monitoring Programs. Our QAPP presents Data Quality Indicators (DQI) that will be used as
a metric to qualify and defend the data generated:
1) Certification -Can th e sample collec tion equipm ent collect sa mples that are unbiased? All
sampling systems used for this study will be "Certified" to shown that they have the ability to
provide unbiased samples prior to being deployed.
2) Detectability -Is the analy ti cal me thodology s ensitive enough to meas ure th e con ce ntration
ran ges exp ec ted during th e s tudy? ERG 's offers some of the lowest experimentally determined
Method Detection Limits (MDL) available. For the target compounds of interest, our MDLs
are lower than the associated risk v alues (i .e ., for both risk screening and health risk
determination).
3) Precision -Is th e method precise? A collocated sample will be collected for 10 percent of the
sampling episodes. These collocated samples and the primary counterpart samples will be
analyzed and compared to each other to determine the associated percent Coefficient of
Variance (%CV). The determined %CV will be assessed to determine if it meets the
specification set forth in ERG 's EPA Approved QAPP.
4) Bias (or accuracy) -I s th e me thod able to provid e da ta that do es not systema ti cally deviate
from th e tru e concentration? For both T0-15 and T0-1 lA, ERG is regularly audited for
accuracy through the analysis of "Blind Performance Evaluations Samples" provided by
EPA/OAQPS . This audit process provides a measurement ofERG 's analytical accuracy
expressed as Relative Percent Difference (RPD). Our determined RPD will be assessed to
determine if it meets the specification set forth in ERG 's EPA Approved QAPP.
Con s ideration #2. Is th e data repres entative of th e s tudy area ?
The goal here is to be able to generate a measurements data set that provides a representative cross-
section assessment of emission types and sites that can be used to assess emission rate/totals and
associated risk on a city wide basis. To do this , ERG will determine/perform the following :
Jun e 24, 2010 Page 10 of 14
ERG Response to City of Fort Worth's Formal Questions
1) What are the applicable emission source types involved?
2) Based on any available data (i.e., permit information, AP-42 information, past
measurements data, etc.) determine each source types potential for emissions and rank them
from highest to lowest.
3) Using similar past data, determine the sheer numbers of each source type and rank them
from highest to lowest.
4) Use the 2 rankings to determine which source types provide the most potential for
emissions/risk.
5) Screen a subset of each source type using the IR camera to identify appropriate candidates
for testing based on emissions (i.e., the greater the emissions level viewed -the higher the
potential as a candidate).
6) Select a minimum of 2 sites in each source test.
7) Measure the total VOC emissions from each candidate site as methane using the API
bagging approach of the Hi-flow approach (Initial -before speciated sampling and analysis
begins).
8) Using the total VOC as methane data, conduct modeling to determine the potential for
transport.
9) Using annual and seasonal (i.e., August and September for the last 3 years) wind speed and
wind direction data from the closest National Weather Service station to generate wind
roses to determine the most likely predominate wind direction that will be encountered
during the study.
10) Establish down wind monitoring sites, at a distance consistent with any applicable set-back
ordinances, from each source type site to be studied.
11) Collect time integrated 24-hour samples (i.e., from midnight to midnight) on a l-in-3 day
frequency .
12) Measure the total VOC emissions as methane from emission type site studies using the API
bagging approach of the Hi-flow approach (Final -after speciated sampling and analysis
ends).
This approach will provide a data set that is representative of the variety of source types and emissions
rates (with an emphasis on potential worst case), and produce a data set with a population large enough
to characterize emissions and risk potential on a city-wide basis.
Point Source Testing
The ERG/Sage team considers that defensible conclusions about point source emissions in the Fort
Worth metropolitan area can only be derived from a study that inspects all potential natural gas point
sources via IR camera. This "Phase I" screening tool will ensure that a comprehensive cross-section of
sources are ultimately tested based on location, and based on leak rate profiles (such as high, medium,
or low) as discussed in our proposal.
In determining the number of sources needed to provide a statistically robust sampling size, we would
draw upon the results of our initial screening effort (Phase 1 ). Conducting an IR camera survey of all
potential point sources of hydrocarbon leaks is quick, scientifically sound, and considered essential to
holding the confidence of the Fort Worth community. Conversely, an incomplete survey could result in
weakened ambient air monitoring and modeling results and a discouraged community. The IR camera
is an effective tool for surveying large areas and finding big leaks fast. To save time , two IR camera
teams are proposed with each team assigned specific survey grids. All accessible wells, natural gas
June 24, 2010 Page 11 of 14
ERG Response to City of Fort Worth's Formal Questions
processing facilities , and compressor stations within the assigned grids will be visited and surveyed for
em1ss1ons.
The IR camera helps you find large leaks, but it does not tell you how much is leaking. In order to
determine how much is leaking, the component's emission rate needs to be measured. Emission rate
measurements are possible in minutes with the High-Flo® sampler and to the extent possible, emission
rates from leaking components will be determined using this device. However, some components are
going to be too large or located in spots inaccessible to the High-Flo ® sampler. For these components,
a Method 21 screening value plus the EPA screening correlation factors will be relied upon to quickly
derive estimated emission rates .
June 24, 2010 Page 12 of 14
ERG Response to City of Fort Worth's Formal Questions
Question 8 -If there is some need to reduce the scope of the proposed study because of cost or time
constraints, how would you identify what pieces of the study would be eliminated and what pieces
would be retained?
If cost and/or time re s traints become issues for the City, then we can offer several broad areas of the
proposed study that the City may want to rev isit from the original Request for Qualifications. These
considerations are li sted below:
Ambient Monitoring Considerations
For any study of this nature Technical Objectives (i .e., what are the goals that are trying to be achieved
through this study) must b e established at the on-set. This allows Data Quality Objectiv e s (i.e., how
good does the data need to be to meet the needs of the data users in accomplishing the Technical
Objectives). Typically, in a study of this nature, multiple Technical Objectives will be identified. The
ideal situation would be to make scope reductions that would still allow all of the determined Technical
Objectiv e s to be met, still with an acceptable level of confidence in the conclusions. In the case of this
study, ERG would consider two primary elements.
Elem ent #1 would be the possibility of reducing the frequency of sample collection (i .e ., change ov er to
a 1-in 6 day). In this , ERG would have to determine if the change would result in a data set population
that was still representative and reasonable to use to accomplish the Technical Objectives of the study.
Elem ent #2 would be the possibility of reducing the number of Technical Objectives. At first
as se ssment, all o f the multiple Technical Objectives initially identified typically appear to be equal in
importance. However, if asse s sed further in a prudent and objectiv e manner, they usually can be
prioritized. When the prioritization is complete, work related to the Technical Objective of highest
importance would be conducted. This approach would continue for each of the other identified
Technical Objectives in order of priority until the available funding level or associated time constraint
was reached. For example, the RFQ appears to place a priority on benzene, methane, ethane, and VOC
from wells , gathering stations, and compressor stations, so the City may consider postponing ev aluation
ofNOx and PM emissions, a s well a s emissions from mobile sources.
These elements w ould be considered s eparately and in combination to achieve the most beneficial final
produce/approach achievable.
Dispersion Modeling Considerations
Elem ent #1 : Remove air dispersion modeling component. This is based on the premise that collection
of high-quality ambient air quality and meteorological data of the highest quality is the most important.
It is necessary to give the community immediate feedback on what they are actually being exposed to.
Dispersion modeling is theoretical and could likely confuse the public, without thorough explanations
and context. That said, the air dispersion modeling is probably the least costly part of the study; so , the
amount of savings are not likely extraordinary.
Elem ent #2: Limit the number of proposed s ites. Although sev eral areas of the city are affected by the
industry, it is most cost-effective to intensely study just a handful of sites , while getting a representative
sample across the various phases of the gas drilling and production cycle. Pick a representative site for
each, utilizing exis ting information gathered from TCEQ activ ities .
June 24 , 2010 Page 13 of 14
ERG Response to City of Fort Worth's Formal Questions
Element #3 : Conduct air dispersion modeling in a "regulatory" mode . This analysis is probably the
least costly, and.would involve conducting air dispersion modeling in a mode similar to what industrial
facilities do for permits. Model "permissible" or permitted emissions from the facilities, along with
TCEQ model-ready meteorological data . This analysis could be conducted both on a local level (i.e.,
pick a worst-case facility based on emission le vels or prior monitored concentrations). This is not a
"real-world" analysis . This analysis provides an estimate of what the maximum impacts could be.
This analysis eliminates collecting field measurements (assuming emission inventory data are already
available and reasonably quality-assured). The downside of this approach is the modeling analysis
will most likely overestimate impacts , due to the conservative modeling assumptions. However, if
conservative results obtained using worst-case assumptions are below concentrations of concern, a
large degree of confidence is achieved that the public is not being subjected to overly adverse air
quality.
Point Source Testing Considerations
Reductions to the scope for the proposed point source characterization effort would be recommended in
the following order:
Elem ent #1: Do not survey transmission lines. As newer equipment is installed in the field , the use of
older transmission lines has been reduced . Newer transmission lines are expected to have minimal
leaking components. Therefore, emissions from this category may be insignificant r elative to other
sources .
Elem ent #2: Do not collect emission rate data from components in which the IR camera does not detect
a leak. Although component count is important, the emissions from components with no observed
leaks (based on the IR screening) may be insignificant relative to other sources .
Elem ent #3: An alternativ e to conducting an IR camera ground survey of all point sources , survey only
a statistically determined representative sample of point sources and extrapolate the results to the entire
population. Additionally, we can use EPA 's most recent National-scale Air Toxics Assessment
(NATA) modeling results to identify census tracts in the Fort Worth and surrounding areas where the
cancer and/or noncancer risk is elevated.
June 24, 2010 Page 14 of 14